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Visibility Rankings  | | #126 out of 6,240 lawyers in Cleveland, Ohio | | #22,085 out of 898,912 total lawyers Overall |
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| Practice Areas | Tax | | | Education | Cleveland-Marshall College of Law, J.D., summa cum laude, 2000; Cleveland State Law Review, Executive Editor, Bowling Green State University, B.A., summa cum laude, 1997 Phi Beta Kappa; Faculty Award, 2nd Highest GPA Class of 2000 | | | Admitted | 2000, Ohio | |
| Memberships | American Bar Association (Member, Section of Taxation, 2001—; Vice-chair, 2007-2008 and Member, 2001—, Administrative Practice Committee; Chair, 2004 and Vice-chair, 2001-2003, Important Development Subcommittee); Cleveland Metropolitan Bar Association; Cleveland Tax Institute (Panel Chair, 2007; Speaker, 2003-2004, 2006, 2007; Vice-chair, Arrangements Committee, 2001-2002); Tax Club of Cleveland. | | | Biography | Greg is an associate in the Tax practice group, focusing his practice on federal and state tax controversies. He has represented numerous clients in IRS audits and administrative appeals, and he has extensive experience obtaining rulings from IRS National Office. Greg has been a principal participant in tax litigation matters docketed in federal district court, U.S. Court of Federal Claims, U.S. Tax Court, and the Ohio Board of Tax Appeals. He also has assisted with appeals to the Sixth Circuit Court of Appeals and the Ohio Supreme Court. Greg also advises clients with respect to corporate mergers and acquisitions and partnership tax issues. Greg has significant experience with leasing, insurance, TEFRA partnerships, tax credits, tax refund procedures, debt/equity disputes, net operating loss limitations, penalty defense and abatement, business purpose/economic substance, and attorney-client/work product privileges. Greg is active in the ABA Tax Section, where he is Vice-Chair of the Administrative Practice Committee and was named a John S. Nolan Fellow for 2005-2006, a "distinction awarded to young lawyers who are actively involved in the Section and who have shown leadership qualities." REPRESENTATIVE MATTERS: FEDERAL TAX CONTROVERSY MATTERS: Member of litigation team for Fortune 500 manufacturer in refund suit for interest netting in Court of Federal Claims; defeated government's motion to dismiss on procedural issue; negotiated settlement.; Co-counsel for Fortune 1000 manufacturer in docketed United States Tax Court case concerning large loss on sale of subsidiary; obtained full concession from IRS counsel in settlement.; Member of litigation team for Fortune 500 bank in economic substance / substance over form case in federal district court; partial settlement.; Co-counsel for Fortune 500 utility defending $90 million research credit refund claim before IRS Examination and Technical Specialists.; Member of legal team that obtained favorable pre-filing agreement with respect to $90 million abandonment loss of large multi-national corporation.; Co-counsel in saving $76 million for Fortune 500 utility by obtaining favorable ruling from IRS National Office concerning utilization of capital losses.; Co-counsel in obtaining favorable ruling from IRS National Office for Fortune 1000 manufacturer concerning $72 million loss on sale of accounts receivables.; Member of legal team that obtained concession from IRS Appeals, preserving over $20 million of bad debt deductions for large manufacturer.; Member of legal team that obtained $11 million concession from IRS Appeals in dispute with large utility company over tax characterization of receipts.; Co-counsel in obtaining favorable settlement from IRS Appeals, preserving over $3 million of bad debt deductions for corporate shareholder.; Co-counsel in obtaining favorable ruling from IRS National Office, preserving over $1 million in low-income housing tax credits for investors.; Obtained abatement of over $500,000 in federal civil penalties for individual's failure to file foreign trust returns.; Counsel for numerous corporate clients with respect to large refund review procedures, including reporting to Joint Committee on Taxation.; Counsel for numerous clients concerning tax accrual workpapers and privilege issues. TRANSACTIONAL MATTERS: Counseled Fortune 100 financial institution with respect to placement of $1.5 billion of Bank Owned Life Insurance.; Advised Fortune 1000 corporation on simplification of organizational structure, including mergers of subsidiaries and evaluation of tiered partnerships.; Advised corporate client on structuring transfer of substantially all of assets as a tax-free reorganization.; Counseled large private foundation on restructuring and potential merger.; Counseled property and casualty insurer with respect to structuring captive insurance arrangement.; Advised investors with respect to structure of true lease agreements in connection with larger sale of senior housing facilities.; Advised investors with respect to conditional sale agreements in connection with new markets tax credit transaction.; Counseled investors concerning aspects of rehabilitation tax credit and low-income housing tax credit transactions, including the intricacies of placed-in-service requirements.; Counseled numerous corporate clients on aspects of consolidated groups, including excess loss accounts and the continuation/termination of the group as the result of a corporate restructuring.; Advised numerous corporate clients on ownership changes and net operating loss carry forward limitations under Section 382. OHIO TAX MATTERS: Lead counsel representing individual in docketed case before Ohio Board of Tax Appeals concerning responsible officer liability for state sales tax; negotiated favorable settlement.; Counsel to large electric utility concerning proposed Ohio tangible personal property tax assessment and true value determination.; Advised real estate developers concerning state tax issues associated with asset acquisitions. PROFESSIONAL & CIVIC INVOLVEMENT: PROFESSIONAL ASSOCIATIONS: American Bar Association, Member; Cleveland Metropolitan Bar Association, Member; Cleveland-Marshall Law Alumni Association, Member. PROFESSIONAL ACTIVITIES: Section of Taxation, American Bar Association, Member (2001-Present); Administrative Practice Committee (Vice-chair, 2007-2008; Member, 2001 - Present); Important Development Subcommittee (Chair 2004; Vice-chair 2001-2003); Cleveland Tax Institute: Panel Chair (2007); Speaker (2003-2004, 2006, 2007), Vice-chair Arrangements Committee (2001-2002); Tax Club of Cleveland, Member (2001-Present). COMMUNITY ACTIVITIES: City of Seven Hills Zoning Board of Appeals (Member 2004 - 2007). PUBLICATIONS: BOOKS: "Representation Before the United States Tax Court", (Thomson-West), co-author. ARTICLES: "Joint Committee Refund Review: 12 Questions to Consider," Journal of Tax Practice and Procedure, October-November 2008, co-author; "Top 10 Tax Stories of 2004," Journal of Tax Practice and Procedure, February-March 2005; "Tax Accrual Workpapers: IRS Efforts to Obtain Them, Corporate Strategies to Protect Them," The Tax Executive, September-October 2003, co-author; "Rethinking Refund Review: Understanding the Joint Committee on Taxation," Corporate Business Taxation Monthly, Volume 4, No. 2, 2002, co-author. PRESENTATIONS: "Changing Atmosphere of Tax Controversy", Tax Executives Institute Meeting Niagara Frontier Chapter, May 1, 2007; American Bar Association, Section of Taxation, Regular speaker on Important Developments in Administrative Practice, Joint Committee on Taxation Refund Review Procedures; Cleveland Tax Institute, List Maintenance Requirements Under Section 6112, Joint Committee Refund Review Procedures, Responding to Information Document Requests and Summons Enforcement Actions, Penalty Abatement and Reasonable Cause Defense. AWARDS & HONORS: John S. Nolan Fellow (2005 - 2006 Class; American Bar Association Section of Taxation). | | | ISLN | 915623646 | |
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