Sidley Austin LLP announced that Matthew D. Lerner has joined the firm’s Washington, D.C. office as a partner and a co-global coordinator of the Tax Controversy practice.
Mr. Lerner has nearly 30 years of experience practicing in the area of federal taxation, with substantial experience in civil and criminal tax controversies and civil litigation related to tax strategies, as well as business planning and advice. His experience broadly covers all stages of the Internal Revenue Service’s administrative audit and appeals processes, as well as litigation in Tax Court, the Court of Federal Claims and federal district courts. He is experienced in handling tax controversies for corporations, partnerships and individuals, and has significant experience with many of the IRS alternative dispute resolution procedures. He also regularly advises on pre-audit issues regarding document organization, retention practices and disclosure obligations. Mr. Lerner also handles state and local tax controversies.
Mr. Lerner has been recognized for his accomplishments and is nationally ranked inChambers USA and America’s Leading Business Lawyers. He regularly publishes on tax issues and is a frequent speaker at tax conferences, including the prestigious Tax Executive Institute.
“I have known Matt professionally and personally for many years,” said Jay Zimbler, global coordinator of Sidley’s Tax Controversy practice. “He has a broad range of experience and deep understanding of tax controversy issues, as well as high intellect and integrity. We are excited that he has joined our team of lawyers providing counsel to clients in federal and state tax disputes nationwide.”
“Matt’s depth of knowledge on various tax issues and litigation skills will be a valuable asset to our clients and an excellent complement to the firm’s global practice,” said Mark Hopson, managing partner of Sidley’s Washington, D.C. office and member of the firm’s Management Committee. “We look forward to working with Matt to serve our clients.”
Mr. Lerner was ranked by Chambers USA in 2012 and 2013 for America’s Leading Business Lawyers, Tax Controversy: Nationwide. The Best Lawyers of America recognized Mr. Lerner in 2012, 2013 and 2014 for Tax Litigation and Controversy. Additionally, Legal 500 US 2013 recommended Mr. Lerner for Tax: Controversy and Domestic Tax: East Coast.
Withers Bergman has hired two experienced tax controversy partners. Both join from Hass & Hecht/WeiserMazars with Moise being based in New York and Cohen in New Haven.
Seth Cohen represents individuals and entities in tax controversies, including federal,
state and local tax examinations and appeals; criminal tax matters; tax litigation; and voluntary disclosure agreements (both offshore and domestic). Additionally, assisting clients in relation to tax collection procedures, including tax liens and levies, as well as collection administrative appeals, installment agreements and offers in compromise.
He is also Adjunct Professor at the University of New Haven.
David Moise has over 25 years of experience providing services in the tax procedure and controversy area. He specializes in federal, state and local tax examinations and appeals, tax court litigation, and voluntary disclosure agreements. In addition, David has extensive experience in relation to Tax Collection procedures, including tax liens and levies, as well as collection administrative appeals, installment agreements and Offers in Compromise.
David is an attorney admitted to practice law in the State of New York and before the United States Tax Court. David received his B.A. at Syracuse University, his J.D. at Pace University School of Law, and an LL.M. in Taxation at Boston University.
alliantgroup has announced the appointment of Kathy Petronchak, former IRS Commissioner of Small Business/Self- Employed Division (SB/SE), as the firm’s Director of IRS Dispute Resolution. Petronchak brings with her 34 years of experience in directing IRS compliance activities and providing tax controversy services. In her new role, Petronchak will be reaching out to CPAs and American businesses, helping alliantgroup’s clients navigate IRS procedures and the U.S. tax code.
“I am excited for the opportunity to join this exceptional team,” Petronchak said. “I am looking forward to serving as an advisor for our clients and in helping CPAs and U.S. businesses better understand the options available to them in resolving disputes with the IRS.”
In a career that includes service within both the federal government and the private sector, Petronchak has worked with a countless number of businesses in examination from both the government’s perspective and in the position of audit defense. In her 29 years with the IRS, she has held a number of roles within the Service, including her time as IRS Commissioner of SB/SE from 2006-2008, a role in which she worked directly with small and mid-sized businesses and practitioners on compliance with IRS standards. She was also appointed Chief of Staff under former IRS Commissioner and current alliantgroup Vice Chairman,Mark W. Everson, and was highly praised for the leadership she brought to this position.
“It is a privilege to be working again with Kathy Petronchak,” Everson said. “The judgment Kathy brings from her extensive experience across different IRS operations will be a real asset to alliantgroup and the businesses we serve.”
Petronchak has served as the Chair of the AICPA IRS Practice and Procedures Committee and currently serves as the immediate past chair. She has also been a frequent speaker for AICPA tax controversy conference events. Most recently, Petronchak was a Director at Deloitte Tax LLP, where she specialized in the area of tax controversy services, providing support for clients in their issues with the IRS. In her new role, Petronchak will be advising businesses of all sizes in their dealings with the Service, helping them identify options for resolving disputes.
“I am thrilled to have Kathy join our team here at alliantgroup,” said alliantgroup COO Shane T. Frank. “Her experience with the IRS and knowledge of the Service’s standards will serve our clients well in navigating IRS waters.”
Irwin Mitchell, has boosted its commercial practice with the announcement that it has appointed leading tax investigations partner, Phil Berwick, from Pinsent Masons.
Based in the firm’s London office, Phil is the 19th new partner to be announced by Irwin Mitchell’s commercial practice this since the start of 2012 and follows other recent lateral hires including new head of commercial litigation, Nigel Kissack, and intellectual property specialists Alex Newman and Georgie Collins.
A former inspector of taxes, Phil left the Inland Revenue 18 years ago and worked in the investigation teams of various accountancy and consultancy firms, spending four years as head of tax investigations at Tenon. He joined McGrigors, the law firm which subsequently merged with Pinsent Masons, in 2009, as head of their tax investigations team.
Phil deals with a range of HMRC’s specialist units, but is principally involved in investigations instigated by HMRC’s Specialist Investigations and Local Compliance Fraud teams. He is a recognised expert and innovator in relation to advising clients on international disclosure facilities. His clients includecorporate entities, individuals, sole traders and partnerships, and he frequently assists professional advisers who seek his specialist expertise.
Commenting on his appointment, Phil Berwick said: “Irwin Mitchell is a very attractive proposition and it presents me with an exciting opportunity to build a market-leading tax investigations and disputes team.
“I firmly believe that there is enormous potential for growth. HMRC continues to take an increasingly tougher stance on avoidance as well as evasion, and clients need to take specialist advice. Another growth area is international disclose facility work, and I believe Irwin Mitchell is ideally positioned in this fast-changing market to ensure that it can capitalise on the opportunities which will present themselves.”
Niall Baker, partner and chief executive of Irwin Mitchell’s Business Legal Services (BLS) division, said: “This appointment speaks volumes for our determination to keep expanding and is a further sign that senior advisers, not just lawyers, are excited about what we are doing and want to be part of it.
“Phil is an important strategic hire and exactly the type of person we are looking to bring into Irwin Mitchell. He is a vastly experienced operator, an innovator, a market leading expert in his field, and someone who enhances the range of services that we can offer to the business legal market.”
Steptoe & Johnson LLP has announced that Rob Kovacev, a former senior litigation counsel in the US Department of Justice’s (DOJ) Tax Division, has joined the firm as a partner. Mr. Kovacev’s arrival continues the expansion of Steptoe’s Tax Group, which welcomed partner Bob Rizzi in October.
As senior litigation counsel in the DOJ’s Tax Division, Mr. Kovacev litigated high-profile civil tax cases and developed substantial trial experience. He was lead trial counsel in several complex tax cases involving cross-border transactions, Section 482 disputes, claims for research credits and foreign tax credits, corporate reorganizations and acquisitions, and valuation of pharmaceutical patents and other intellectual property. The amounts at issue in each of these cases ranged from $10 million to more than $1 billion in claimed tax benefits. Mr. Kovacev was also lead counsel in several summons enforcement matters of the highest priority to the IRS.
While at the DOJ, Mr. Kovacev gained particular experience regarding the IRS’s use of the economic substance, substance over form, and sham partnership doctrines to disallow the tax benefits of transactions that comply with the technical requirements of the tax code. For example, Mr. Kovacev was lead trial counsel for the United States in AWG Leasing, involving a cross-border leveraged leasing transaction. The court in AWG Leasing disallowed over $100 million in tax benefits from that transaction, and sustained the IRS’s determination of penalties against the taxpayer. Mr. Kovacev was also on the trial team for the Southgate Master Fundcase, in which the court disallowed more than $1 billion in tax benefits arising from a distressed debt transaction based on the court’s interpretation of the sham partnership doctrine.
In welcoming Mr. Kovacev to Steptoe, firm Chair Roger Warin commented: “Our tax controversy practice has been a mainstay of our Tax Group for decades. Rob will help bolster the next generation of lead tax controversy partners with a smart, effective, well-credentialed tax litigator who has first-chair trial experience in significant cases.”
Steptoe’s Tax Controversy practice includes experienced litigators who have served as Justice Department trial and appellate attorneys, judicial law clerks, and Treasury officials. The practice combines trial-tested litigation skills with up-to-date substantive tax experience. Steptoe’s highly regarded tax group has earned top rankings and recommendations from the prestigious legal directories Chambers USA and The Legal 500, among other publications.
“Steptoe’s tax practice has a superb reputation, and I’m delighted to be a part of it,” said Mr. Kovacev. “As the IRS and DOJ Tax Division deploy tax shelter tools against transactions that are not generally considered abusive tax shelters, unwary taxpayers will be caught surprised. I look forward to using the experience I gained as a DOJ tax litigator to help taxpayers meet the challenges they will face in this new environment.”
Mr. Kovacev won several awards for his work at the DOJ Tax Division, including the John Marshall Award for Trial of Litigation, the Tax Division’s Outstanding Attorney award (three times), and the Mitchell Rogovin Award, the IRS’s award for outstanding support to the Office of Chief Counsel.
A magna cum laude graduate of Harvard College, Mr. Kovacev earned his J.D. from Columbia Law School, where he was a senior editor of the Columbia Law Review, a Kent Scholar and a Stone Scholar. He clerked for the Honorable M. Blane Michael on the US Circuit Court of Appeals for the 4th Circuit and worked in private practice before joining the government in 2006.
King & Wood Mallesons has announced the promotion of Jerome Tse to the partnership, with effect from 1 December.
Jerome has been with the Firm in Sydney since 2008 and has specialised in tax since 2001, when he trained with PwC. He focuses on corporate tax advice and tax controversy issues.
George Abney has joined Alston & Bird as a partner in the firm’s Tax Controversy Group.
Mr. Abney has significant trial and appellate experience gained from years as a federal prosecutor with the Tax Division of the U.S. Department of Justice in Washington, D.C., and as an assistant U.S. attorney in the Northern District of Florida. In private practice, he has successfully represented clients in civil tax controversies before the IRS, the U.S. Tax Court, the U.S. district courts and the U.S. bankruptcy courts, as well as in federal grand jury investigations and IRS criminal investigations.
Mr. Abney was recognized by former Attorney General John Ashcroft as a Tax Division Outstanding Attorney, and he has received special recognition from FBI Director Robert S. Mueller, III, for his work in successfully prosecuting United States v. Dugas, a case that involved kidnapping, Mann Act and firearms charges.
Mr. Abney earned his J.D. from the Florida State University College of Law, with high honors, where he served as executive editor of the law review, and his B.A. from Columbia University.
Brown, PC, the Texas-based boutique law firm with a nationwide US practice handling tax controversies and tax litigation, has announced the addition of experienced tax attorney Cynthia Cook as senior counsel.
Ms. Cook has special expertise representing clients in civil and criminal tax cases, IRS audits and appeals, and business and employment tax matters. With more than two decades of experience, she provides sophisticated and effective counsel for clients in matters before the U.S. Tax Court, U.S. Court of Federal Claims, U.S. District Courts, 5th U.S. Circuit Court of Appeals and the Internal Revenue Service (IRS).
In addition to her law degree from the University of Kansas School of Law, Ms. Cook earned her Master of Laws in Taxation from the Southern Methodist University Dedman School of Law. She secured her undergraduate degree from Wichita State University..
“At Brown, PC, our experienced attorneys and veteran former IRS investigators and accountants take a team approach to high-level, high-stakes litigation involving civil and criminal tax matters,” says firm founder Lawrence Brown. “Cynthia’s extensive legal experience and specific tax expertise will make her a key member of our team.”
Founded in 1992, Brown, PC, represents clients in the most complex IRS audits and appeals, civil tax litigation, asset forfeiture actions, IRS criminal tax matters and IRS tax collection disputes. The firm’s clients include ultra-high-net-worth individuals and businesses located throughout the United States and around the world.