Mr. Ruchelman is a member in Caplin & Drysdale's Washington, D.C. office, where he concentrates his practice in tax litigation and controversies with the Internal Revenue Service and other tax authorities. He also represents clients in general tax matters.
Services
Mr. Ruchelman has extensive experience in resolving tax matters at all stages of tax disputes including IRS examinations, IRS appeals, post-appeals mediation, trial court litigation, and appellate litigation. He has litigated cases in the U.S. Tax Court, various U.S. district courts, and the U.S. Court of Federal Claims.
Highlights
· Represented a large Wall Street financial services firm in appeal to the 7th Circuit Court of Appeals (JPMorgan Chase & Co. v. C.I.R. , 530 F.3d 634 (7th Cir. 2008)).
· Represented a hedge fund and its tax matters partner in a three-way IRS examination that led to litigation with the IRS and an adverse partner in the U.S. Court of Federal Claims (Imprimis Investors LLC v. United States, 83 Fed. CI. 46 (2008)).
· Successfully defended Hawaii Department of Taxation and its employees against unlawful disclosure claims in the U.S. District Court (Marsoun v. United States, 525 F. Supp.2d 206 (D. D.C. 2007)).
· Represented an international accounting firm in litigation concerning privilege issues (United States v. BDO Seidman LLP, 2004 WL 1470034 (N.D. Ill, June 28, 2004)).
· Represented a tax attorney in proceedings brought by the IRS Office of Professional Responsibility in the U.S. administrative court. IRS conceded significant issues on the eve of trial.
· Achieved a favorable settlement for a high-net-worth family in an IRS examination involving family limited partnership issues.
· Attained a favorable settlement for a high-net-worth individual in an IRS examination involving a contribution of a conservation easement.
· Successfully resolved an examination involving promoter penalty issues in IRS post-appeals mediation.
Other Representative Matters
Mr. Ruchelman has represented clients before the IRS examination division, IRS Appeals, or in court involving the following substantive tax issues: IRS collections, family limited partnerships, contributions of conservation easements; estate and gift taxes, oil and gas partnerships, residency issues, restricted interest, employee benefits, and tax shelter disclosures. He also has considerable experience responding to IRS third-party summonses.
Government Experience
Before joining Caplin & Drysdale, Mr. Ruchelman was a Trial Attorney with the U.S. Department of Justice, Tax Division, and an Attorney with the Internal Revenue Service, Office of Chief Counsel.
While at the Department of Justice, he litigated tax cases in the federal district courts and the U.S. Court of Federal Claims. For his work representing the government in extended trials involving the IRS's attack on leveraged corporate-owned life insurance as a tax shelter, Mr. Ruchelman received the Attorney General's Distinguished Service Award.
Professional Activities
Mr. Ruchelman recently completed his tenure as Chairman of the Tax Audits and Litigation Committee for the Tax Section of the D.C. Bar. This committee presented monthly panel discussions on hot topics in the tax audits and litigation arena and frequently interacted with IRS and DOJ tax officials. He is also an active member of the American Bar Association Section of Taxation, the Court of Federal Claims Bar Association, and the U.S. Tax Court's J. Edgar Murdoch Inns of Court.
Awards & Honors
Ranked as a leading lawyer in Tax Controversy in the 2011 edition of The Legal 500.
Other Professional Affiliations
Chair, D.C. Bar (Tax Section, Tax Audits and Litigation Committee)
American Bar Association (Section of Taxation)
U.S. Tax Court's J. Edgar Murdock Inns of Court
Government Experience
U.S. Department of Justice, Tax Division, 1996-2003
IRS Office of Chief Counsel, 1993-1996