Ronald A. Levitt

Ronald A. Levitt: Attorney with Sirote & Permutt, P.C.
  • Shareholder at Sirote & Permutt, P.C. (108 Attorneys)
  • 2311 Highland Avenue South, P.O. Box 55727, Birmingham, AL 35205
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Biography

Ronald’s practice focuses on two main areas of practice. First, he handles federal and state controversy matters, including planning and defending conservation easements. Second, his practice focuses on business and tax planning, particularly for closely held and family owned businesses. Specifically, he counsels clients in business planning, succession planning, estate planning, charitable deduction planning, entity formation, representation of S Corporations, Limited Liability Companies and other flow-through entities, mergers and acquisitions, purchases and sales of businesses, and healthcare law (representing physician practices).

Awards & Accreditations

•Best Lawyers in America
•Mid-South Super Lawyers
•AV-Preeminent, Martindale-Hubbell Peer Review Rating

Professional Profile

Recognition

•The Best Lawyers in America
•Tax Law, 1995-2018
•Corporate Law, 2008-2018
•Health Care Law, 2008-2018
•Litigation and Controversy-Tax, 2011-2018
•Best Lawyers 2012 Tax Law Lawyer of the Year in Birmingham
•Mid-South Super Lawyers, 2008-2018
•AV-Preeminent, Martindale-Hubbell Peer Review Rating

Birmingham Magazine, Top Attorney in Tax Law, 2009-2010

Thought Leadership

•Practice focuses on federal and state controversy matters, planning and defending conservation easements, business and tax planning, particularly for closely held and family-owned businesses
•Co-author of Treatise, Tax Planning for S Corporations, Second Edition, LexisNexis
•Editor, Sirote Tax Controversy Blog
•Editor, Sirote Conservation Easement Blog
•Author, Sirote Corporate & Tax Planning Blog

Outside the Office

American Bar Foundation
Fellow
N.E. Miles Jewish Day School
Board of Directors, Former Member
Birmingham Holocaust Education Center
Board of Directors, Former Member
Temple Beth-El
Vice President, 2016-present
Board of Directors
Temple Beth-El Foundation
Board of Directors
A.G. Gaston Boys & Girls Club
Board of Directors, Former Member
Helen Keller Foundation
Board of Directors
NCCJ (Local Chapter)
Board of Directors, Former Member
Temple Emanu-El
Vice President, 2006-2009
Board of Directors, Former Member
Levite Jewish Community Center
President, 1995-1996
Board of Directors, Former Member
Birmingham Jewish Federation
First Vice President (Campaign Chair) 1997-98
Board of Directors, Former Member
Birmingham Jewish Foundation
Board of Directors, Former Member

Speeches & Publications

Conservation Easement

•Co-authored, “T ax Court Disallows Developer’s 11,040,000 Charitable Deduction: Characterizes PUD Plan Approval Process as Quid Pro Quo Arrangement. ” June 18, 2018
•Co-authored, “Confusion Following the Death of the Conservation Easement” Enhancement Regulation, ” April 11, 2018
•Co-authored, “Can RERI Holdings I, LLC Co-Existing Tax Court Precedent Regarding Conservation Easement Donations?” October 24, 2017
•Co-authored, “RERI Holdings I, LLC: What the Basis? ’ August 28, 2017
•Authored, “Ronald Levitt quoted in Daily Tax Report Article: “Partnership-Owned Easements Safe with Solid Appraisals,” August 24, 2017
•Co-authored, “The Fifth Circuit Corrals “Belk” in “Bosque Canyon, ” August 22, 2017
•Co-authored, “The Fifth Circuit Overturns Tax Court in Bosque Canyon... the Belk Stops Here!” August 17, 2017
•Co-authored, “Conservation Easement Listed Transactions; New Notice 2017-29 (Or: The Good, The Bad and the Ugly-Sorry Clint Eastwood?),” April 28, 2017
•Co-authored, “Summa Holdings, Inc. pins the IRS in a rematch bout-Sixth Circuit counts IRS out.” February 24, 2017
•Speaker, “Land Conservation: The Worth of The Earth” 23 rd Annual Public Interest Environmental Conference, February 10, 2017
•Speaker and Co-authored: NYU’s 75th Institute on Federal Taxation; Planning for and Defending Conservation Easements in an Adverse IRS Environment, San Diego, California, November 17, 2016
•Speaker: NYU’s 75th Institute on Federal Taxation; Planning for and Defending Conservation Easements in an Adverse IRS Environment, New York, NY, San Diego, California, October 27, 2016
•Co-authored, “Tax Court Denies deduction for Conservation Easement Due to Failure to Timely Subordinate Mortgages, ” May 10, 2016
•Co-authored, “Court Denies Conservation Easement Deduction on Technical Grounds: No Nit Is Too Small for the IRS to Pick, ” May 5, 2016
•Authored, “US Senators Complain to IRS Commissioner About Over-Aggressive Audit Tactics in Audits of Conservation Easement Donations, ” February 24, 2016
•Co-authored, “Easement Donors Find Themselves Without a “Legg: to Stand on in Penalty Case, ” February 17, 2016
•Co-author, Navigating the Defenses to Valuation Penalties in Charitable Deduction Cases, Journal of Taxation, December 2014
•Co-author, “Conservation Easement Confusion in the Tax Court and Fifth Circuit, ” Real Estate Taxation, 2013
•Co-author, What is Conservation Easement? The Counselor, Fall 2013
•Co-author, Circuit Courts Speak on Conservation Easements, But is the IRS Listening? Taxation of Exempts, January 2013
•Co-author, Proving the Value of a Charitable Donation May Be the Least of Your Problems, Journal of Taxation Vol. 115/No. 2, 2011
•Co-author, Tax Court Analysis of Land Conservation Easements Values - Developments Since Kiva Dunes, Taxation of Exempts Vol. 2/No.6, 2011
•Co-author, “A Guide to Donating Conservation Easements Substantiating Their Value”, Valuation Strategies, May/June 2010 Edition
•Co-author, “Kiva Dunes-Making and Substantiating the Value of Conservation Easements”, Journal of Taxation, November 2009

Tax

•Speaker, 141 st Alabama State Bar Annual Meeting & Legal Expo, Miramar Beach, Florida, June 29, 2018
•Co-authored, “Tax Court Disallows Developer’s 11,040,000 Charitable Deduction: Characterizes PUD Plan Approval Process as Quid Pro Quo Arrangement.” June 18, 2018
•Speaker, 99 th Alabama Society of CPAs Annual Meeting in Montgomery, Alabama, June 14, 2018
•Speaker, American Bar Association’s Annual Tax Section May Meeting, Washington, DC, May 11, 2018
•Speaker, CCIM Institute Webinar on “Capitalizing on Tax Reform,” April 4, 2018
•Authored, “Notice 2018-006: How will the Government comply with Section 6751(b)? Greg Rhodes Quoted in MLex US Tax Watch Article, ” June 28, 2018
•Co-authored, “Update on Hurricanes Irma, Harvey, and Maria Disaster Relief: The IRS has a Change of Heart Regarding the Filing Deadlines for IRS Form 8886.” October 2, 2017
•Co-authored, “Listed Transaction Update: Hurricane Disaster Relief Does NOT Extend the October 2, 2017 Deadline to File IRS Form 8886, ” September 28, 2017
•Co-authored, “For Whom the Statute Tolls? The IRS.” June 5, 2017
•Co-authored, “Tax Court Upholds Penalty for Failure to Disclose a Listed Transaction Notwithstanding Eighth Amendment “Excessive Fine” Argument, ” February 6, 2017
•Co-authored, “Notice 2017-10-A Dirty Santa Gift Land Trusts and Others Don’t Want to Claim, ” January 19, 2017
•Co-authored, “Tax Court Slams IRS Penalty Argument: Penalties Abated Due to Reliance on CPA, ” August 15, 2017
•Co-authored, “Real Estate Professionals-Substantiation and Logic Reign Supreme in Demonstrating Real Estate Professional Status, ” May 8, 2017
•Speaker, The Florida Tax Institute on “Hot Topics for S Corporations,” Tampa, Florida, March 29-31, 2017
•Co-authored, “Summa Holdings, Inc. pins the IRS in a rematch bout-Sixth Circuit counts IRS out, ” February 21, 2017
•Co-authored, “The Tax Court Upholds Penalty for Failure to Disclose a Listed Transaction Notwithstanding Eighth Amendment “Excessive Fine” Argument, ” February 13, 2017
•Co-authored, “Eleventh Circuit Expounds on “Reasonable Probability” and “HBU” in Important Taxpayer-Favorable Opinion, ” February 23, 2016
•Co-authored, “Pro Se Taxpayers in Facade Easement Case Doomed to Gross Valuation Penalty by Self-Inflicted Errors, ” February 19, 2016
•Co-authored, “In A Taxpayer Friendly Reasonable Compensation Case... Independent Investor Test Explained, ” May 18, 2016
•Co-authored, “Ninth Circuit Affirms Denial of Deduction of “Management Fees”-Recordkeeping and Documentation of Services Provided Found Lacking, ” March 2, 2016
•Co-author of Treatise, Tax Planning for S Corporations, Second Edition, LexisNexis
•Speaker: 70th Annual Federal Tax Clinic; Reasonable Compensation for C and S Corporations, Tuscaloosa, Alabama, November 18, 2016
•Author, ArtPlay: Providing a Stage for Everyone in Our Community, Sirote Supports, September 2013
•Co-author, Due Diligence Issues Arising in Connection with the Acquisition of an S Corporation, Journal of Taxation Vol.115/No.1, 2011
•Co-author, You May Live Abroad, but You Still Have to File at Home!, The Counselor, Year End 2011
•Co-author, “Simmons-Substantial Compliance Revisited”, Tax Notes, January 2010
•Co-author, Operation of the Professional Corporation 2010: Reasonable Compensation Issues for Professional and Other Services Businesses, NYU 69th Annual Institute on Federal Taxation 1, 2011
•Co-author, Reasonable Compensation and the Build-In Gains Tax, NYU 68th Annual Institute on Federal Taxation 15, 2010
•Co-author, Real Estate Dealer vs. Investor: Maximizing Capital Gains, NYU 67th Annual Institute on Federal Taxation 9, 2009
•Co-author, Operating as an S Corporations Through a State Law Limited Liability Company, NYU 66th Annual Institute on Federal Taxation 17, 2008
•Co-author, The Uncertainty of Basis Increases in Connection with Back-to-Back Loans to S Corporations, Business Entities, January/February 2007
•Co-author, So You Think It’s Easy to Obtain Basis Increases for Loans to S-Corps? Think Again! Opportunities and Pitfalls in Structuring and Restructuring Loans to S Corporations, NYU 65th Annual Institute on Federal Taxations 15, 2007
•Co-author, Shareholder Agreements for Closely Held Corporations, 15 Business Entities 20, 2003Co-author, Back to Back Loans, which was presented at the 65th New York University Institute on Federal Taxation in October/November 2006
•Co-author, Redemptions and Purchases of S Corporation Stock, NYU 64th Annual Institute on Federal Taxation, October/November 2005; 63rd Annual Institute on Federal Taxation, October/November 2004
•Co-author, Avoiding Unreasonable Compensation Attacks on Professional Service and Other Closely Held Corporations, published in BNA’s Executive Compensation Library, 2004
•Co-author Reasonable Compensation Issues for Closely-Held and Service Companies, which was presented at the 61st New York University Institute on Federal Taxation (61 N.Y.U. Ann. Inst. Fed. Tax’n 16 (2003))
•Co-author, Drafting Shareholder Agreements for Closely-Held C and S Corporations, which was presented at the 60th New York University Institute on Federal Taxation (60 N.Y.U. Ann. Inst. Fed. Tax’n 18 (2002))
•Author, What RRA ‘93 Giveth and Taketh Away: Investment Incentives and Revenue Raisers, 5 Journal of S Corporation Taxation 339, 1994
•Author, Will the Real One-Class-of-Stock Rule Please Stand Up? 2 Journal of S Corporation Taxation 25, 1991
•Speaker:
•ABA Tax Section Programs and Committee Meetings;
•Alabama Association of Accountants and Tax Preparers;
•Alabama Society of CPAs;
•Alabama Society of Enrolled Agents;
•American College of Trust & Estate Counsel;
•American Institute on Federal Taxation;
•Birmingham Tax Forum;
•Chattanooga Tax Practitioners;
•Conservation Easements Seminar;
•Florida Tax Institute; Atlanta Tax Forum;
•Great Lakes Federal Tax Institute;
•LTA Rallies; Oregon Tax Institute;
•Heart of America Tax Conference;
•Land Trust Alliance;
•New York University Institute on Taxation;
•Tennessee Tax Institute;
•Savannah Tax Forum;
•Southern Federal Tax Institute;
•University of Alabama Federal Tax Clinic;
•University of North Carolina Tax Conference;
•University of Texas Taxation Conference;
•University of Virginia Tax Clinic

News

Sirote & Permutt Attorneys to Speak at 99th Alabama Society of CPAs Annual Meeting in Montgomery, Alabama, on June 14 - 6/11/2018
Sirote is proud to announce that Attorneys Ronald A. Levitt and Gregory P. Rhodes spoke at the American Bar Association’s Annual Tax Section May Meeting in DC on current tax issues, topics and legislation on May 11th - 5/14/2018
Sirote Attorneys Ronald Levitt and Brad Sklar featured on CCIM Institute’s Webinar - 4/4/2018
Sirote & Permutt Announces 47 Attorneys Selected as The Best Lawyers in America for 2016 - 8/17/2015
Sirote & Permutt Presents Alabama Society of CPA Seminar Series - 7/14/2015
Sirote & Permutt Announces 28 Attorneys Selected As Alabama Super Lawyers 2015 - 5/27/2015
Ronald Levitt to Speak at American Bar Association Tax Section Meeting - 1/29/2015
Chris Bottcher Presents Lawyering Across Generations at the Association of Professional Responsibility Lawyers Conference - 1/27/2015
Daily Tax Report Quotes Ronald Levitt - 1/9/2015
Ronald Levitt Quoted in Two Bloomberg BNA Articles - 12/2/2014
Sirote & Permutt’s Ronald Levitt and David Wooldridge Quoted in Business Alabama Article on Kiva Dunes Case - 8/25/2014
Sirote & Permutt Attorneys Included in The Best Lawyers in America for 2015 - 8/19/2014
Sirote & Permutt Presents ASCPA Webinar Series - 7/1/2014
Sirote’s Ronald Levitt to Speak About Conservation Easement - 6/5/2014
Sirote & Permutt Attorneys to Speak at 95th Alabama Society of CPAs Annual Meeting - 6/3/2014
Sirote’s Tax Litigation Lawyers File Brief in Appeal of 2.1 Million Conservation Easement Deduction - 5/16/2014
Sirote & Permutt Announces 28 Attorneys Selected As Alabama Super Lawyers 2014 - 4/28/2014
Sirote Attorneys Shirley Justice and Ronald Levitt To Lead Presentation On The Affordable Care Act’s Tax Implications - 1/7/2014
Alabama Society of Enrolled Agents Invites Sirote Attorneys to Speak About Health Care - 10/25/2013
Ronald Levitt Speaks Nationally About Tax Issues - 10/23/2013
Ronald Levitt and David Wooldridge Speak about Conservation Easements - 9/25/2013
Attorneys Speak about Tax Issues to the Alabama Association of Accountants & Tax Preparers - 9/20/2013
Sirote Attorneys Ronald Levitt and David Wooldridge to Serve as Panelists for the Land Trust Alliance - 9/9/2013
Sirote Attorneys Ronald Levitt and Brad Sklar to Speak about LLC’s at ASCPA Webinar - 9/3/2013
Best Lawyers Recognizes 46 Sirote Attorneys as the Best Lawyers in America for 2014 - 8/16/2013
Sirote & Permutt Present ASCPA Hot Topics in Tax Webinar Series - 7/25/2013
Sirote’s Ronald Levitt Speaks About Environmental Capitalism and Investment Opportunities - 6/24/2013
Sirote & Permutt Announces 30 Attorneys Selected as Alabama Super Lawyers 2013 - 6/14/2013
Sirote’s Ronald Levitt Speaks about S-Corporations and LLC Mergers - 5/30/2013
Sirote & Permutt Hosts a Free Seminar About Health Care Law - 5/2/2013
Sirote’s Ronald Levitt to Present Estate Planning Webinar - 4/8/2013
Sirote’s Ronald Levitt Warns of Looming Tax Issues for S Corporation Owners - 3/13/2013
Ronald Levitt Offers Important 2013 Tax News for All Business Owners - 12/12/2012
Sirote Legal Alert: The Changing Tax Climate - 12/10/2012
Best Lawyers Recognizes 43 Attorneys from Sirote & Permutt as the Best Lawyers in America for 2013 - 11/5/2012
Register Now For Sirote-ASCPA Seminar Presented by Ronald Levitt - 8/8/2012
Seminar for CPA, Banking, and Commercial Real Estate industries! - 8/3/2012
Ronald Levitt Presenter for ASCPA Webinar - 7/18/2012
Corporate, Tax and Estate Planning Attorneys Speak at ASCPA Annual Meeting - 6/22/2012
Ronald Levitt Co-Author for LexisNexis Tax Planning Book - 6/4/2012
Sirote & Permutt Lawyers in the Tax Press - 5/9/2012
Sirote Attorneys Levitt and Wooldridge Elected to American College of Tax Counsel - 4/24/2012
Sirote & Permutt Successfully Defends Case Against IRS - 3/12/2012
Ronald Levitt to Moderate Panel at ABA Tax Section Meeting - 2/15/2012
Ronald Levitt Speaks on Current Topics Affecting S-Corporations - 11/22/2011
Six Sirote Attorneys Designated Best Lawyers of the Year for 2012 - 11/17/2011
Ronald Levitt and David Wooldridge to Present at Conservation Easement Conference - 10/31/2011
Sirote Tax Attorneys Publish Land Easement Article - 7/21/2011
Best Lawyers has selected 32 attorneys from Sirote & Permutt for recognition in The Best Lawyers in America for 2011 - 8/27/2010
Birmingham Magazine Names 5 From Sirote As Top Attorneys - 3/2/2010
31 Sirote Attorneys Listed In Best Lawyers - 8/7/2009
Sirote & Permutt Attorneys Have Successful Outcome In Landmark Conservation Easement Case Before US Tax Court - 6/22/2009
Publication Recognizes 20 From Sirote As Super Lawyers - 5/19/2009
Sirote Shareholder Levitt To Speak AT UNC Tax Institute - 4/16/2009
Birmingham Magazine Recognizes 17 From Sirote As Top Attorneys - 3/10/2009

American College of Tax Counsel; Adjunct Professor: University of Alabama School of Law LL.M. in Taxation Program (Partnership Taxation); Cumberland School of Law (Partnership Taxation). President: Federal Tax Clinic, Inc., 1995; Birmingham Tax Forum, 2003-2004. Frequent instructor for the American Bar Association Tax Section, the New York University Institute on Federal Taxation, the Alabama Society of CPAs, the Tennessee Tax Institute, the Federal Tax Clinic, Inc., the Birmingham Tax Forum and other organizations. Publications: "Back to Back Loans," presented at the 65th New York University Institute on Federal Taxation in October/November 2006; "The Uncertainty of Basis Increases in Connection with Back-to-Back Loans to S Corporations," published in Business Entities magazine, January/February 2007; "Redemptions and Purchases of S Corporation Stock," presented at the 63rd New York University Institute on Federal Taxation in October/November, 2005; "Avoiding Unreasonable Compensation Attacks on Professional Service and Other Closely Held Corporations," published in BNA's Executive Compensation Library, (2004); "Shareholder Agreements for Closely Held Corporations," 15 Business Entities 20, 2003; "Reasonable Compensation Issues for Closely-Held and Service Companies," presented at the 61st New York University Institute on Federal Taxation (61 N.Y.U. Ann. Inst. Fed. Tax'n § 16, 2003); "Drafting Shareholder Agreements for Closely-Held C and S Corporations," presented at the 60th New York University Institute on Federal Taxation (60 N.Y.U. Ann. Inst. Fed. Tax'n § 18, 2002); "What RRA '93 Giveth and Taketh Away: Investment Incentives and Revenue Raisers," 5 Journal of S Corporation Taxation 339, 1994; "Will the Real One-Class-of-Stock Rule Please Stand Up?" 2 Journal of S Corporation Taxation 251, 1991. Member: Birmingham (Member, 1984—) and American (Member, Taxation Law Section, 1985—; Member, 1985—, Vice-Chair, 2000-2004 and Chair, 2004—, Committee on S Corporations) Bar Associations; Alabama State Bar (Member, Taxation Section, 1985—, Vice-Chair, 1990-1991 and Chair, 1991-1992).

Areas of Practice (14)

  • Business & Succession Planning
  • Charitable Planning & Contributions
  • Closely Owned & Family Business Planning
  • Conservation Easements
  • Corporate & Securities
  • Estate Planning & Administration
  • Health Care
  • Industrials & Natural Resources
  • Real Estate
  • Tax
  • Tax Controversy & Litigation
  • Tax Planning
  • Trust & Estate Litigation
  • Wealth Management & Succession

Education & Credentials

Contact Information:
205.930.5274  Phone
205.212.3894  Fax
www.sirote.com
University Attended:
University of Alabama, B.S., cum laude, 1979; University of Alabama, M.B.A., 1983
Law School Attended:
University of Alabama, J.D., 1983; University of Florida, LL.M., Taxation, 1984
Year of First admission:
1983
Admission:
1983, Alabama
Memberships:

Organizations

•American Bar Association, Tax Section, Council Director; and S-Corporation Committee, Former Chair
•American Bar Foundation, Alabama Fellow
•American College of Tax Counsel, Fellow; Former Regents
•Federal Tax Clinic, Former President
•Birmingham Tax Forum, Former President
•Alabama State Bar, Tax Section, Former Chair
•Leadership Birmingham, Class of 1996

Birth Information:
Denver, Colorado, November 11, 1957
ISLN:
905478515

Peer Reviews

  • 5.0/5.0 (1 review)
  • A Martindale-Hubbell Peer Rating reflects a combination of achieving a Very High General Ethical Standards rating and a Legal Ability numerical rating.
  • Legal Knowledge

    5.0/5.0
  • Analytical Capability

    5.0/5.0
  • Judgment

    5.0/5.0
  • Communication

    5.0/5.0
  • Legal Experience

    5.0/5.0
  • 5.0/5.0 Rated by a Partner on 04/10/14 in Tax Law

    I have known Ronald since law school and know him to be an excellent lawyer.

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