University of New MexicoB.A., Anderson School of Management, Finance, 1990
University of New Mexico School of LawJ.D., 1995
- New Mexico
- Certified Tax Specialist – State Bar of Arizona
Caylor Land and Development v. Commissioner, awaiting opinion, - U.S. Tax Court – issue of first impression involving deductibility of insurance expenses paid to a micro-captive insurance company pursuant to IRC section 831(b).
Kline v. Commissioner, T.C. Memo. 2015-144 – U.S. Tax Court – case involving material participation in a Caribbean yacht chartering business. Application of IRC section 469 and Treas. Reg. 1.469-5T(a)(3) when using a charter management company.
Slone v. Commissioner, T.C. Memo 2012-57 – U.S. Tax Court – case involving transferee liability for corporate income taxes attributable to a purported intermediary tax shelter.
David Dung Le, MD, Inc. v. Commissioner, 114 T.C. 268 (2000) – U.S. Tax Court – issue of first impression involving corporate entity’s capacity to bring suit in Tax Court to dispute Statutory Notice of Deficiency.
David Dung Le v. Commissioner, 86 T.C.M. 116 (2003) – U.S. Tax Court – case involving civil tax fraud and individual transferee liability arising from closely held “C” corporation.
John S. Fagan v. Commissioner, T.C. Memo. 2001-222 – U.S. Tax Court – case involving civil tax fraud and partial summary judgment.
Letantia Bussell v. Commissioner, T.C. Memo. 2005-77 – U.S. Tax Court – case involving civil tax fraud and claim of innocent spouse relief.
Kathryn Bernal v. Commissioner, 120 T.C. 102 (2003) – U.S. Tax Court – issue of first impression involving Tax Court’s jurisdiction to review denial of innocent spouse claim made pursuant to IRC section 66.
Julian O. Von Kalinowski v. Commissioner, T.C. Memo. 2001-21 – United States Tax Court – case involving innocent spouse relief and constructive knowledge if duty of inquiry is not met.
- State Bar of Arizona Tax Section – Member at Large
- Lawyers on Call – State Bar of Arizona
- Small Captives, Big Issues: A Discussion of 831(b) from Audit to Appeals to the Courtroom, State Bar of Arizona, Tax Section - 2017
- IRC section 831(b) Captive Insurance Audits and Litigation, Western Regional Captive Insurance Conference, 2016
- The Ongoing Battle between Captives and the IRS, Arizona Captive Insurance Association, 2015
- Divorce-Related Tax Issues, State Bar of Arizona, Family Law Section, 2015