Professional Experience
Charlie Lenore practices in the area of state and federal tax law.
Charlie's tax practice includes Connecticut tax matters, on which he is a well-known speaker and author. In addition to tax planning and counseling, Charlie also counsels and represents clients in state tax matters in other states, including New York and Massachusetts. Charlie has extensive experience litigating tax cases before the Connecticut Tax Court and the Connecticut Supreme Court, and frequently serves on taskforces established by the Connecticut General Assembly and the Department of Revenue Services on tax/policy initiatives. Charlie is the chair of the Tax Committee of the Connecticut Business and Industry Association.
Charlie's federal tax experience includes acquisitions and dispositions of businesses, international operations, and executive compensation matters. In addition, Charlie is frequently involved in developing state tax strategies to complement the chosen federal tax strategy.
Representative Matters
· Sikorsky Aircraft Corp. v. Commissioner, SC 18302 (Ct. Supreme Court 2010); sales and use tax refund affirmed-exemption for research and development equipment used in manufacturing of aircraft parts and components
· Rainforest Café, Inc. v. Commissioner, 293 Conn. 363 (Ct. Supreme Court 2009), as amicus counsel for the Connecticut Business and Industry Association; sales and use tax held that failure to follow non-resident contractor statutes did not constitute "intent to evade"
· HVT, Inc. v. Commissioner, SC 18296 (Ct. Supreme Court 2009) as amicus counsel to the Association of Consumer Vehicle Lessors; payment of property tax on leased vehicle by lessee held subject to sales tax
· Achillion Pharmaceuticals, Inc. v. Commissioner, 291 Conn. 525 (2009); corporation business tax-appeal denied, taxpayer not entitled to exchange R&D tax credit carryforwards under state refund program
· Message Center Management, Inc. v. Pam Law, Commissioner of Revenue Services, CT Supreme Court (June 19, 2007); sales and use tax-affirmed Tax Court determination that Message Center's services were not taxable
· Sikorsky Aircraft Corporation v. Pam Law, Commissioner of Revenue Services, CT Tax Court (May 16, 2007); sales and use tax-exemption for research and development equipment used in the manufacturing of aircraft parts and components
· Pratt & Whitney Division of United Technologies Corp. et al. v. Commissioner, CT Tax Court (July 3, 2002); sales and use tax-exemption for research and development equipment used in the manufacturing of aircraft parts and components
· Andersen Consulting LLP v. Gavin, CT Supreme Court (March 19, 2001); sales and use tax-taxation of custom software
· Eastman Kodak, Inc. v. Gavin, CT Tax Court (May 26, 2000); corporation business tax-deductibility of commissions paid to a FSC
· Connecticut Yankee Atomic Power Co. v. Gavin, CT Tax Court (April 27, 2000); sales and use tax-exemption from taxation of services for disposal of radioactive waste
· Berkley v. Gavin, CT Supreme Court (July 25, 2000); personal income tax-application of tax benefit rule to personal income tax
· United Technologies Corp. v. Groppo, 238 Conn. 774 (1996); sales and use tax-exemption for property purchased in connection with government contracts
· Minnesota Mining and Manufacturing Co. v. Crystal, CT Tax Court (March 30, 1995); corporation business tax-due date for filing amended return
· Pechiney Corp. v. Crystal, CT Tax Court (January 13, 1994; Section 1983 claim in tax case
· Kelley-Springfield Tire Co. v. Bajorski, 228 Conn. 137 (1993) (P.L. 86-272)
· National Cleaning Contractors, Inc. v. Meehan, CT Tax Court (November 29, 1993); sales and use tax-services to real property
· Trans-Lux Corp. v. Meehan, CT Tax Court (December 3, 1993); corporation business tax-Section 12-226a
· United Technologies Corp. v. Groppo, 220 Conn. 665 (1991); corporation business tax-alternative tax
· Texaco, Inc. v. Groppo, 215 Conn. 134 (1990); petroleum gross earnings tax-amicus counsel
· Hartford Parkview Assoc. Limited Partnership v. Groppo, 211 Conn. 246 (1989); sales and use tax-computer services
· Northeast Datacom, Inc. v. Wallingford, 212 Conn. 639 (1989); property tax on software-amicus counsel
· AMAX, Inc. v. Groppo, 17 Conn. App. 82 (1988); corporation business tax-apportionment
· Golf Digest/Tennis, Inc. v. Dubno, 203 Conn. 455 (1987); use of NOLs following merger
News, Publications & Presentations
· "Governor Signs Bill Capping Taxes on Gasoline," State Tax Notes, April 9, 2012
· "Governor Creates Business Tax Credit Review Task Force," State Tax Notes, January 23, 2012
· Featured, "Fifty Day Pitney Attorneys Recognized as Super Lawyers," Day Pitney Press Release, October 24, 2011
· "Payroll Processing Problems May Affect Withholding," State Tax Notes, August 22, 2011
· "Connecticut Lawmakers Approve Updates to Budget Provisions," State Tax Notes, June 13, 2011
· "Connecticut Governor Signs Tax Package," State Tax Notes, May 9, 2011
· "Connecticut Governor, Lawmakers Agree on Budget," State Tax Notes, April 25, 2011
· "Taxwriters Consider 'Amazon' Law," State Tax Notes, April 4, 2011
· "Taxwriters to Take Up Combined Reporting Bill," State Tax Notes, March 28, 2011
· "Connecticut Governor Proposes $3 Billion in Tax Increases," State Tax Notes, February 21, 2011
· Featured, "Fifty-seven Day Pitney Attorneys Recognized as Super Lawyers; Six Additional Lawyers Recognized as 'Rising Stars'," Day Pitney Press Release, November 12, 2010
· Featured, "Seventy-six Day Pitney Lawyers Named to Best Lawyers for 2011," Day Pitney Press Release, August 9, 2010
· "Lawmakers Approve Municipal Real Estate Tax Extension," State Tax Notes, June 28, 2010
· "Connecticut Governor Vetoes TARP Bonus Tax," State Tax Notes, May 24, 2010
· "Connecticut Lawmakers Approve Tax Credit Package," State Tax Notes, May 10, 2010
· Co-author, "Connecticut Tax Credit Incentivizes Angel Investment in Start-up Businesses," Day Pitney Alert, May 7, 2010
· "Connecticut Taxwriters Approve Unitary Combined Reporting," State Tax Notes, April 12, 2010
· "Panel Approves Tax on Bonuses From Federal Bailout Recipients," State Tax Notes, April 12, 2010
· "Tax Panel to Consider Amazon Law, Annual Review of Credits," State Tax Notes, March 15, 2010
· "Governor Proposes Job Creation Initiatives," State Tax Notes, February 8, 2010
· "Connecticut Governor Vetoes Estate Tax Cut Delay," State Tax Notes, January 4, 2010
· "Connecticut Sales Tax Cut Will Not Take Effect," State Tax Notes, December 7, 2009
· "Connecticut Adopts 14-Day Withholding Rule," State Tax Notes, December 7, 2009
· "DOR Guidance on Catch-Up Withholding Released," State Tax Notes, November 16, 2009
· Speaker, "Nexus Update: Indirect Nexus, Telecommuting, and the Sourcing of Service Revenues," CSCPA Tax 360 Conference, November 10, 2009
· Featured, "Fifty-six Day Pitney Partners Recognized as New England Super Lawyers," Day Pitney Press Release, October 30, 2009
· "State Releases Details of Settlement Incentive Program," State Tax Notes, October 19, 2009
· "State Announces Offshore Voluntary Disclosure Program," State Tax Notes, October 5, 2009
· "Connecticut Lawmakers Approve Budget With Tax Increases," State Tax Notes, September 7, 2009
· "Connecticut Governor Offers Compromise Budget," State Tax Notes, August 31, 2009
· "Connecticut Governor Proposes Revised Budget, Tax Increases," State Tax Notes, August 10, 2009
· Featured, "Seventy-seven Day Pitney Partners Named to Best Lawyers 2010," Day Pitney Press Release, July 30, 2009
· "State to Increase Business Registration Enforcement," State Tax Notes, July 27, 2009
· "Governor to Veto Democratic Budget Bill," State Tax Notes, July 6, 2009
· "State Enacts Higher Penalty for Unregistered Foreign Corporations," State Tax Notes, June 15, 2009
· "Governor Proposes 'No Tax' Budget," State Tax Notes, June 8, 2009
· Speaker, "Connecticut Tax Development," Tax Executives Institute, Rocky Hill, CT, April 29, 2009
· "Finance Panel Approves Higher Taxes," State Tax Notes, April 13, 2009
· Speaker, "State Fiscal Policy," Connecticut Business and Industry Association, March 17, 2009
· "Finance Panel to Hold Hearing On New Income Tax Rates, Other Measures," State Tax Notes, March 9, 2009
· "Finance Panel to Hold Hearing On Corporation Tax Surcharge, Sales Tax Increase," State Tax Notes, March 2, 2009
· "Taxwriters to Consider Moratorium, Cap on Credits," State Tax Notes, February 9, 2009
· "Finance Panel to Hold Hearing On Combined Reporting," State Tax Notes, February 9, 2009
· "Governor Proposes Budget Without Tax Increases," State Tax Notes, February 9, 2009
· "Governor Calls For State Spending Cuts To Address Deficit," State Tax Notes, January 12, 2009
· "Revenue Department Releases Details on Upcoming Amnesty," State Tax Notes, January 12, 2009
Professional Affiliations
· Connecticut Business and Industry Association, Tax Committee, chair, 2007-present
· New England State and Local Tax Forum, Board of Advisors, 2012-present
· Connecticut General Assembly, Business Tax Credit and Tax Policy Review Committee, 2005-2008
· Connecticut General Assembly, Streamlined Sales Tax Commission, 2007-2008
· Department of Revenue Services Carpenter Technology Ad Hoc Committee, co-chair with Commissioner Gene Gavin, 2001
· Hartford Chamber of Commerce, director, 2001-2007
· Department of Revenue Services Factor Relief for Manufacturers Study Committee, 1999
· MetroHartford Alliance, Tax/Fiscal Policies Committee, 1990-present
· Connecticut General Assembly, Sales and Use Task Force, 1997-1998
· MIT Enterprise Forum of Connecticut, Inc., director, 1988-1994
· Connecticut General Assembly, State Tax Review Commission, chairman, 1991-1994
· Connecticut General Assembly, Task Forces on State Taxation, 1986-1987; 1989-1990
Awards and Achievements
· Recognized as a Connecticut Super Lawyer, 2007-2011/2012
· Chosen for inclusion in The Best Lawyers in America, Tax Law, 2011 and for over 10 years