Michelle Ferreira counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county Assessment Appeals Boards. As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages. Michelle was the former Chair of the Executive Committee of the Taxation Section of the California State Bar in 2009-2010. Michelle speaks frequently on topics of tax controversy and tax procedure before professional associations for both lawyers and accountants, and she was an adjunct professor for the Master's in Taxation Program at Golden Gate University in San Francisco. Outside of the office, Michelle is involved in a wide-array of tax professional organizations and has established key relationships with IRS and state taxing agency executives. Michelle is nationally recognized for her audit and litigation experience in estate and gift tax disputes with the IRS, especially cases involving challenges to family limited partnerships and valuation disputes. Areas of Concentration ˇ Tax compliance advice ˇ Civil tax disputes, including audits, appeals, and collection matters ˇ Offshore income tax disputes, foreign income, bank and asset reporting and related penalty assessments ˇ Complex tax litigation ˇ Criminal tax investigations and litigation ˇ Tax penalties ˇ Tax shelter investigations, audit and litigation ˇ Taxing agencies' information document requests ˇ Tax procedure ˇ Tax shelter promoter audits and investigations ˇ Estate and gift tax disputes Significant Representations Michelle has 17 reported decisions in the United States Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions and unsubstantiated business expenses. Professional & Community Involvement ˇ Chair, Executive Committee, Tax Section of the California State Bar, 2009-2010 ˇ Executive Committee, National Association of State Bar Tax Sections ˇ Executive Committee, Taxation Section, 2006, 2007, 2008 ˇ Taxation Section of the California State Bar ˇ American Bar Association, Taxation Section ˇ San Francisco Tax Club ˇ San Francisco Estate Planning Council Awards & Recognition ˇ Nominee, 2010 Tax Person of the Year, Tax Analysts, January 2011 ˇ Listed, The Best Lawyers in America, Tax Law, 2011 ˇ Listed Northern California Super Lawyers, 2008-2011 ˇ Certificate of Appreciation, May, 2002, Small Business/Self-Employed Division, IRS ˇ Performance Award, Fall, 2001, Small Business/Self-Employed Division,IRS ˇ Special Act Award, December 1997 for litigation of Estate of Schauerhamer v. Commissioner, T.C. Memo 1997-242 Other Experience ˇ Trial Attorney for the Office of Chief Counsel, Internal Revenue Service ˇ Adjunct Professor, Golden Gate University School of Tax Articles, Publications, & Lectures Articles and Publications ˇ Quoted, "IRS Amnesty Puts Calif. Residents in a Bind," The Recorder, Law.com, January 24, 2012. ˇ Quoted, "Audits of Wealthy Taxpayers Pose Challenges, Practitioners Say." Tax Analysts, September 29, 2011. ˇ Quoted, "Background Checks, Vague Definition Of Tax Preparers Still Worry Practitioners," The Bureau of National Affairs, Inc, Daily Tax Report, January 13, 2011. |