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| Practice Areas | Taxation Law; Tax Litigation; White Collar Crime | | | Education | Hastings College of Law, University of California, J.D., 1971, University of California at Santa Barbara, B.A., 1968 | | | Admitted | 1971, California and U.S. Tax Court; 1973, U.S. District Court, Western District of Washington; 1975, Washington; 1982, U.S. Court of Appeals, 9th Circuit; 1985, U.S. Court of Federal Claims | |
| Memberships | Washington State (Chairman, Federal Tax Administration and Procedures Committee; Member, Governing Council, Taxation Section), Federal and American Bar Associations; Washington State Trial Lawyers Association. | | | Born | Pasadena, California, September 15, 1945 | | | Biography | Teaching, Seminars and Publications: Visiting Professor: University of Washington, School of Law, 1997-1998, Graduate Program in Taxation, Federal Tax Controversies and Procedures; Guest Lecturer: University of Washington, School of Law, 1995 and 1996, Graduate Program in Taxation, Federal Tax Controversies and Procedures; Lecturer and Panelist: Washington State Bar Association, Ethics and Estate Planning and Taxation, December 1996, "Ethical Problems Inherent in Tax Controversies;" Program Chair and Panelist: Washington State Bar Association, Federal Tax Controversies, November 1995, "Ins and Outs of Tax Litigation;" Lecturer: Washington Association of Criminal Defense Lawyers, Tax Considerations for Criminal Defense, June 1994, "The Tax Man Cometh - Maybe"; Panelist and Commentator: Washington Attorney-CPA Tax Clinic, March 1994, "Selected Topics of Import Regarding Tax Practice and Procedures"; Lecturer: Washington State Bar Association, February 1991, "Civil Penalties-Their Restructuring and Effect." Lecturer: University of Washington, Ninth Annual Federal Tax Conference, November 1990, "Civil Penalties-Their Restructuring and Effect," Lecturer: Washington State Bar Association, February 1990, "Dealing with the IRS in the 1990's-Criminal Investigations," Lecturer: and Panelist: Hawaii State Bar Association, January 1990, "How to Deal with the IRS." Lecturer: Northwest Tax Institute, October 1989, "Tax Controversy-Penalties and the Taxpayer Bill of Rights"; Lecturer: University of Washington, Annual Federal Tax Conference, November 1987, "Administration and Procedures." Program Chair and Lecturer: Washington State Bar Association, Tax Controversy and Procedures, January 1986, "Aggressive IRS Collection Efforts-What if Anything you Can Do"; Lecturer: King County Bar Association, October 1985, "Offer In Compromises"; Lecturer: Washington State Bar Association, May 1984, "Tax Shelters"; Lecturer: Golden Gate University Graduate Program in Taxation, 1998. Attorney, Office of Regional Counsel, Internal Revenue Service, Portland, 1971-1972. Senior Trial Attorney, Office of Regional Counsel, Internal Revenue Service, Seattle, 1973-1977. | | | Reported Cases | Dixon v. Commissioner, 90 T.C. 237 (1988); Estate of Vincent Meyer, Deceased, Everett Trust & Sovereign Bank, Trustee v. Commissioner, 66 T.C. 41 (1976); First Northwest Industries of America, Inc. v. Commissioner, 70 T.C. 817 (1978); 649 F.2d 707 (9th Cir. 1981); Freytag v. Commissioner, et. al. 89 T.C. 849 (1987); Jolar Cinema Inc. v. Commissioner, T.C. Memo. 1983-43; Peacock v. Commissioner, 97-282 T.C. Memo, 1997; Petersen v. Commissioner, T.C. Memo. 1987-108; Purvis v. Commissioner, 65 T.C. 1165; Ramberg v. Commissioner, T.C. Memo. 1975-112; Simonson v. Commissioner, T.C. Memo, 1975-012; Tumipseed v. Commissioner, T.C. Memo. 1985-335; United States of America v. Dahlstrom, 713 F.2d 1405 (9th Cir. 1983); University City, Inc. v. Commissioner, T.C. Memo. 1979-198; Winn, et al. v. Commissioner, T.C. Memo. 1997-286; United States v. Elias, 269 F.3d 1003 (9 th Cir. Idaho 2001); Pac. Fisheries, Inc. v. United States, 484 F.3d 1103 (9 th Cir. Wash. 2007); Pac. Fisheries, Inc. v. United States, 539 F.3d 1143 (9 th Cir. Wash. 2008); Gitlitz v. Comm'r, 531 U.S. 206, 121 S. Ct. 701 (2001), rev'g 182 F.3d 1143 (10th Cir. 1999); Sala v. United States, 552 F. Supp.2d 1157 (D. Colo. 2007); Sala v. United States, 552 F. Supp.2d 1167 (D. Colo. 2008). | | | ISLN | 908411120 | |
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