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Profile Visibility  | | #1,492 in weekly profile views out of 10,870 lawyers in Dallas, Texas | | #113,845 in weekly profile views out of 968,565 total lawyers Overall |
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| Practice Areas | Federal Income Tax; Taxation of Natural Resources and Partnerships; Federal Tax Controversies | | | Education | Southern Methodist University, Dedman School of Law, J.D., with honors, 1973, Stephen F. Austin University, B.A., with high honors, 1970 | | | Admitted | 1973, Texas; 1975, U.S. District Court, Northern District of Texas; 1976, U.S. Tax Court; 1977, U.S. Court of Appeals, Third Circuit and U.S. Supreme Court; 1978, U.S. Court of Appeals, Tenth Circuit; 1981, U.S. District Court, Western District of Texas; 1982, U.S. Court of Appeals, Fifth Circuit; 1983, U.S. Court of Federal Claims; 1993, U.S. District Court, Southern District of Texas | |
| Memberships | Dallas (Chair, Tax Section, 1981-1982; Council Member, 1985-1987) and American (Council Director, Tax Section 2006-2008; Chair, Energy & Environmental Committee, 1989-1991; Vice Chair, Appointments to Tax Court Committee, 2000-2001; Member, Court Procedure and Practice Committee; Council Member) Bar Associations; State Bar of Texas (Council, Taxation Section, 1989-1991). | | | Special Agencies | Deputy Chief Counsel, 2002, and Acting Chief Counsel, 2003-2004, Internal Revenue Service. | | | Biography | Named to "America's Leading Lawyers for Business," (Tax, Tax: Litigation Law) Chambers & Partners, Chambers USA, 2006—. Named as Dallas Tax Lawyer of the Year, The Best Lawyers in America, 2010. Listed in: 1983-2010 editions of The Best Lawyers in America (Tax Law); Best Lawyers in Dallas - Tax, D Magazine's, 2001, 2005, 2007-2008;D Magazine's, Best Business Lawyers in Dallas (Tax), 2009; D Magazine's Best Personal Lawyers in Dallas, 2009; Texas Super Lawyers (Tax), 2006—; Top-Notch Lawyer (Tax Law), "Go-To Guide," Texas Lawyer, 2007. Name as: Top 50 Female Attorneys in Texas, Texas Super Lawyers 2008—; Top 100 Dallas/Fort Worth Region, Texas Super Lawyers 2008—. Southern Methodist University (SMU) Dedman School of Law Distinguished Alumni for Government Service, 2007-2008. Adjunct Instructor, Partnership Taxation, Southern Methodist University School of Law, 1984-1986. Chair, Southwestern Legal Foundation Institute on Oil & Gas Taxation, 1987-1989. Publications and Presentations: "My Tax Lawyers' Fingerprints Are on My Transaction - Is That a Problem?," Practicing Law Institute's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings, 2008 conference, Los Angeles, California, December 2008; "Tax Accurals, FIN 48 and Work Product," 16th Annual SMU Corporate Counsel Symposium, Dallas, Texas, October 2008; "Legal and Tax Issues Related to Structuring TIC Transactions," Moderator, Texas Tenant-in-Common Transactions Forum, September 2007; "Ethics and Standards of Tax Practice in the New Age of Transparency: From Self-Assessment to Self-Audit," API (American Petroleum Institute), Federal Tax Forum, Houston, Texas, April 2007; "Surviving IRS Examination and Appeals," March 2006; "IRS Audits and Appeals," co-authored with Robert Probasco, Tax Executives Institute, Dallas Chapter, March 2006; "Fifth Circuit Tax Update," 15 Fifth Circuit Reporter 151, 347, 509, 653, 1998; "The Corporate Taxpayer's Attorney-Client Privilege," 24 J. Corp. Tax. 136, Warren Gorham & Lamont, 1997; "Fifth Circuit Tax Update," 14 Fifth Circuit Reporter 657, 1997; "U.S. Taxation of Technology Transfers and Resulting Income," 9 International Quarterly 645, 1997; "Current Developments in Oil and Gas Taxation," 46th S.W.L.F. Oil & Gas Inst. Ch. 12, Matthew Bender, 1995; Imposition of Texas Corporate Franchise Tax, Texas Tax Service, Ch. 51, Matthew Bender, 1985; "Contributions of Services to the Pool of Capital: General Counsel Memorandum 22730 to Revenue Ruling 83 46," 35th S.W.L.F. Oil & Gas Inst. 313, Matthew Bender, 1984. Fellow: American College of Tax Counsel; Texas Bar Foundation; American Bar Foundation; Dallas Bar Foundation.(Board Certified, Tax Law, Texas Board of Legal Specialization) | | | Reported Cases | Texaco Inc. v. Commissioner, 98 F. 3d 825 (5th Cir. 1997); Estate of Bright v. United States, 658 F.2d 999 (5th Cir. 1981); Gulf Oil Corporation v. Commissioner, 89 T.C. 1010 (1987), 87 T.C. 548 (1986), 87 T.C. 324 (1986), 87 T.C. 135 (1986), 86 T.C. 937 (1986), 86 T.C. 115 (1986), 84 T.C. 447 (1985); Gulf Oil Corporation v. Commissioner, 914 F.2d 396 (3rd Cir. 1990); Gates Rubber Co. v. Commissioner, 694 F.2d 648 (10th Cir. 1982), affirming, 74 T.C. 1456 (1980); General Portland Cement Co. v. United States, 628 F.2d 321 (5th Cir. 1980); Petroleum Corporation of Texas v. United States, 939 F.2d 1165 (5th Cir. 1991); Ranchers Exploration & Development Co. v. United States, 634 F.2d 487 (10th Cir. 1980); Sun Company Inc. v. Commissioner, 677 F.2d 294 (3rd Cir. 1982), affirming, 74 T.C. 1481 (1980); Texaco Inc. v. United States, 598 F. Supp. 1165 (S.D. Tex. 1984); Estate of Street v. Commissioner, T.C. Memo. 1997-32 (1997); CanadianOxy Offshore Production Co. v. Commissioner, 100 T.C. 25 (1993); Natomas North America, Inc. v. Commissioner, 90 T.C. 710 (1988); Transco Exploration Co. v. Commissioner, 949 F.2d 837 (5th Cir. 1992), affirming, 95 T.C. 373 (1991); Bullock v. Mid-American Oil & Gas, Inc., 680 S.W.2d 612 (Tex. App.--Austin 1984, writ ref'd n.r.e.); Rylander v. B&A Marketing, _ S.W.3d _ (Tex. App.--Austin 1999); State of Texas v. Sun Oil Company (Delaware), 740 S.W.2d 556 (Tex. App.--Austin 1987); Estate of True v. Commissioner, T.C. Memo. 1997-167 (2001). | | | ISLN | 904589823 | |
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