Ronald A. Levitt

Ronald A. Levitt: Attorney with Sirote & Permutt, P.C. AV stamp icon
  • Shareholder at Sirote & Permutt, P.C. (112 Attorneys)
  • 2311 Highland Avenue South, P.O. Box 55727, Birmingham, AL 35205
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Attorney Awards

Biography

Ronald’s practice focuses on two main areas. 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, represents S corporations, limited liability companies, and other flow-through entities, mergers and acquisitions, purchases and sales of businesses, and healthcare law by representing physician practices.

Why did you become an attorney?

I always knew I wanted to be a lawyer. But, truthfully, since no one in my immediate family was a lawyer-my dad was a periodontist and my grandparents were business owners-I didn’t know what that meant. I was a business major in college and liked courses that required problem-solving and collaborative work. When I got to law school, the tax- and business-related courses made much more sense to me than most of the litigation-oriented courses. In my second year, I clerked for a couple of tax-oriented firms and through that process learned what “tax school” was. After that, I was hooked. I had found a career that allowed me to work on complex and esoteric issues in a way that helped business owners accomplish their goals. It allowed me to use my strengths in the best way possible and to help solve problems. It is what I was born to do.

Who has inspired you in your career?

I have been inspired by several lawyers with whom I have had to privilege to work. The most notable include Karl Friedman and Abe Berkowitz. I was also inspired by my rabbi, Milton Grafman. Of course, there were many more role models who I could name.All of these folks taught me the value of giving back. They helped mold me as a person; they showed me that my skills and personality are not just useful in helping my clients and friends solve problems but also that my skills can be useful in the not-for-profit world. I’ve spent significant time working in both the Jewish and more general communities. The lawyers and laypersons who inspired me as a young (and no-longer-so-young lawyer) inspired me to use my gifts and talents to help the community as well. They showed me how to do “tikun olom,” which in Hebrew means “repair the world.”

What are you most proud of in your practice?

I am proud of how our team has grown and developed the Tax Controversy Practice Group into a nationally recognized group of talented lawyers. Recognizing the need to form the group, identifying how to proceed, and implementing that plan has been very rewarding, both professionally and personally. It has allowed our firm to develop an area of expertise that is unique in our market and recognized across the nation.

Awards and Accreditations

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

Recognition

•Mid-South Super Lawyers, Tax (2008-2018)
Birmingham Magazine, Top Attorney in Tax Law (2009-2010)
The Best Lawyers in America

•Tax Law (1995-2019)
•Corporate Law (2008-2019)
•Health Care Law (2008-2019)
•Litigation and Controversy - Tax (2011-2019)
Best Lawyers Tax Law Lawyer of the Year in Birmingham (2012)
•AV Preeminent Martindale-Hubbell Peer Review Rating

Thought Leadership

•Co-author of Treatise, Tax Planning for S Corporations, Second Edition, LexisNexis

•Practice focuses on federal and state controversy matters, planning and defending conservation easements, and business and tax planning, particularly for closely held and family-owned businesses

•Speaker at numerous tax clinics, conferences, forums, institutes, programs, seminars, and societies across the nation

Outside the Office

•A.G. Gaston Boys & Girls Club
•Former Member, Board of Directors
•Birmingham Holocaust Education Center
•Former Member, Board of Directors
•Birmingham Jewish Federation
•First Vice President (Campaign Chair) (1997-1998)
•Former Member, Board of Directors
•Birmingham Jewish Foundation
•Current Member, Board of Directors
•Helen Keller Foundation
•Current Member, Board of Directors
•Levite Jewish Community Center
•Former Member, Board of Directors
•President (1995-1996)
•N.E. Miles Jewish Day School
•Former Member, Board of Directors
•National Conference for Community and Justice, Central Alabama Chapter
•Former Member, Board of Directors
•Temple Beth-El
•Board of Directors
•Vice President (2016-2019)
•Temple Emanu-El
•Former Member, Board of Directors
•Vice President (2006-2009)

Speeches and Publications

•Co-author of treatise, Tax Planning for S Corporations: Second Edition, LexisNexis, 2012-2014

National Tax Journals and Seminars

•Speaker and Co-author, Section 199A and Its Impact on Choice of Entity, NYU's 77th Institute on Federal Taxation, New York City, October 28, 2018 and San Diego, November 15, 2018

•Speaker, Section 199A and Its Impact on Choice of Entity, Alabama Federal Tax Clinic, Tuscaloosa, Alabama, November 14, 2018

•Speaker, Section 199A and Its Impact on Choice of Entity, Unreasonably High and Low Compensation Issues, and Operating as an S Corporation through a State Law Limited Liability Company, CPAmerica Tax Conference, New Orleans, Louisiana, November 5, 2018

•Speaker, “Unreasonably High and Low Compensation Issues” and “Operating as an S Corporation Through a State Law Limited Liability Company,” CPAmerica - 2018 Tax Conference, New Orleans, Louisiana, November 5, 2018

•Speaker, “Planning For and Defending Conservation Easements in an Adverse IRS Environment,” 14th Annual Conservation Easement Workshop, Hosted by The Madison-Morgan Conservancy in partnership with the Georgia-Alabama Land Trust (Accredited) and the Atlanta Area Chapter Appraisal Institute, Mansfield, Georgia, September 20, 2018

•Speaker, An Update on Conservation Easements, Alabama Forestry Association Annual Meeting, September 9, 2018

•Speaker, Section 199A and Its Impact on Choice of Entity, Tax Conferences sponsored by the Alabama Society of CPAs - Birmingham, Hunstsville, and Montgomery - September 2018

•Co-author, “IRS Takes Uncharitable View of Property Donation Deductions,” Law 360, August 22, 2018, 4:12 PM EDT

•Speaker, Section 199A and Its Impact on Choice of Entity, NYU's Advanced S Corporation Tax Conference, New York, July 26, 2018

•Speaker, Tax Cuts and Jobs Act of 2017, Alabama State Bar Annual Meeting, June 29, 2018

•Speaker, Section 199A and Its Impact on Choice of Entity, 99th Alabama Society of CPAs Annual Meeting in Montgomery, Alabama, June 14, 2018

•Speaker, Give It Away Now: An Update on Conservation Easements, Charitable Deductions and Substantial Compliance, American Bar Association’s Annual Tax Section May Meeting, Washington, DC, May 11, 2018

•Speaker, “Planning and Defending Conservation Easements in an Adverse Environment,” Cherry Bekaert Tax University, Orlando, Florida, November 7, 2017

•Speaker, Planning and Defending Conservation Easements in an Adverse Tax Environment, Cherry Bekaert Tax University, Orlando, Florida, November 6, 2017

•Speaker, Current Issues Impacting S Corporations, Cherry Bekaert Tax University, Orlando, Florida, November 6, 2017

•Speaker, “Planning for and Defending Conservation Easements in an Adverse IRS Environment,” 16th Annual North Carolina, South Carolina, Georgia, Tax Section Workshop, in Kiawah, South Carolina, May 26-28, 2017

•Speaker, “Land Conservation: The Worth of The Earth,” 23rd Annual Public Interest Environmental Conference, February 10, 2017

•Speaker, Reasonable Compensation for C and S Corporations, 70th Annual Federal Tax Clinic, Tuscaloosa, Alabama, November 18, 2016

•Speaker and Author, Planning for and Defending Conservation Easements in an Adverse IRS Environment, NYU's 75th Institute on Federal Taxation, San Diego, California, November 17, 2016

•Speaker and Author, Planning for and Defending Conservation Easements in an Adverse IRS Environment, NYU's 75th Institute on Federal Taxation, New York, October 27, 2016

•Speaker, “Avoiding Valuation Penalties in Charitable Deduction Cases” and “Defending Conservation Easements in an Adverse Tax Environment,” Portland Tax Forum, Portland, Oregon, October 22, 2015

•Speaker, “Defending Conservation Easements in an Adverse Environment” Florida Tax Institute co-sponsored by the University of Florida Levin College of Law Graduate Tax Program, Tampa, Florida, April 22-24, 2015

•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, 2014

•Co-author, Circuit Courts Speak on Conservation Easements, But Is the IRS Listening?, Taxation of Exempts, January 2013

•Speaker, “Under Fire: Conservation Easement Controversies,” ACTEC - Charitable Planning Committee, June 26, 2011

•Speaker, “Defending Conservation Easements in an Adverse IRS Environment,” 14th Annual Oregon Tax Institute, Portland, Oregon, June 6, 2011

•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, Due Diligence Issues Arising in Connection with the Acquisition of an S Corporation, Journal of Taxation, Vol. 115 No. 1, 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, 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, “A Guide to Donating Conservation Easements: Substantiating Their Value,” Valuation Strategies, May/June 2010

•Co-author, “Simmons-Substantial Compliance Revisited,” Tax Notes, January 2010

•Speaker and Co-author, Reasonable Compensation and the Build-In Gains Tax, NYU 68th Annual Institute on Federal Taxation 15, 2010

•Co-author, “Kiva Dunes-Making and Substantiating the Value of Conservation Easements,” Journal of Taxation, November 2009

•Speaker and Co-author, Real Estate Dealer vs. Investor: Maximizing Capital Gains, NYU 67th Annual Institute on Federal Taxation 9, 2009

•Speaker and 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

•Speaker and 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

•Speaker and Co-author, Back to Back Loans, 65th New York University Institute on Federal Taxation, October/November 2006

•Speaker and 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, BNA's Executive Compensation Library, 2004

•Speaker and Co-author, Reasonable Compensation Issues for Closely Held and Service Companies, 61st New York University Institute on Federal Taxation, 2003

•Co-author, Shareholder Agreements for Closely Held Corporations, 15 Business Entities 20, 2003

•Speaker and Co-author, Drafting Shareholder Agreements for Closely Held C and S Corporations, 60th New York University Institute on Federal Taxation, 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

Editor, The Preserver, Sirote's Conservation Blog

•Co-author, Land Trust Community and the National Taxpayers Union Join Sirote in Urging Fifth Circuit to Reconsider Decision Denying Conservation Easement Deduction and Imposing Penalties, The Preserver, October 12, 2018

•Co-author, 5th Circuit Court of Appeals Muddies the Waters Regarding IRS Compliance with Code Section 6751(b)(1), The Preserver, August 31, 2018

•Co-author, The 5th Circuit Pushes PBBM Down Rose Hill, The Preserver, August 23, 2018

•Co-author, Tax Court Disallows Developer's $11,040,000 Charitable Deduction: Characterizes PUD Plan Approval Process as Quid Pro Quo Arrangement, The Preserver, June 18, 2018

•Co-author, Confusion Following the Death of the Conservation Easement 'Enhancement Regulation,'” The Preserver, April 11, 2018

•Co-author, “Can RERI Holdings I, LLC Co-Existing Tax Court Precedent Regarding Conservation Easement Donations?,” The Preserver, October 24, 2017

•Co-author, “Update on Hurricanes Irma, Harvey, and Maria Disaster Relief: The IRS has a Change of Heart Regarding the Filing Deadlines for IRS Form 8886,” The Preserver, October 2, 2017

•Co-author, “Listed Transaction Update: Hurricane Disaster Relief Does NOT Extend the October 2, 2017 Deadline to File IRS Form 8886,” The Preserver, September 28, 2017

•Co-author, “RERI Holdings I, LLC: What the Basis?,” The Preserver, August 28, 2017

•Co-author, “The Fifth Circuit Corrals 'Belk' in 'Bosque Canyon,'” The Preserver, August 22, 2017

•Co-author, “The Fifth Circuit Overturns Tax Court in Bosque Canyon . . . the Belk Stops Here!,” The Preserver, August 17, 2017

•Co-author, “For Whom the Statute Tolls? The IRS,” The Preserver, June 5, 2017

•Co-author, “Conservation Easement Listed Transactions; New Notice 2017-29 (Or: The Good, The Bad and the Ugly-Sorry Clint Eastwood?),” The Preserver, April 28, 2017

•Co-author, “Summa Holdings, Inc. pins the IRS in a rematch bout-Sixth Circuit counts IRS out,” The Preserver, February 24, 2017

•Co-author, “Tax Court Upholds Penalty for Failure to Disclose a Listed Transaction Notwithstanding Eighth Amendment 'Excessive Fine' Argument,” The Preserver, February 6, 2017

•Co-author, “Notice 2017-10-A Dirty Santa Gift Land Trusts and Others Don’t Want to Claim,” The Preserver, January 19, 2017

•Co-author, “Tax Court Denies Deduction for Conservation Easement Due to Failure to Timely Subordinate Mortgages,” The Preserver, May 10, 2016

•Author, “US Senators Complain to IRS Commissioner About Over-Aggressive Audit Tactics in Audits of Conservation Easement Donations,” The Preserver, February 24, 2016

•Co-author, “Eleventh Circuit Expounds on 'Reasonable Probability' and 'HBU' in Important Taxpayer-Favorable Opinion,” The Preserver, February 23, 2016

•Co-author, “Pro Se Taxpayers in Facade Easement Case Doomed to Gross Valuation Penalty by Self-Inflicted Errors,” The Preserver, February 19, 2016

•Co-author, “Easement Donors Find Themselves Without a 'Legg' to Stand on in Penalty Case,” The Preserver, February 17, 2016

•Co-author, LTA Advises Land Trusts to Continue Including Amendment Clauses and Derides IRS Position, The Preserver, December 8, 2015

•Co-author, More Details on IRS Position on Amendment Clauses, The Preserver, December 4, 2015

•Co-author, Bosque Decision's Ruling on Gross Valuation Penalty - 'The Play is Under Further Review,' The Preserver, November 5, 2015

•Co-author, Bosque Canyon Ranch - conservation easement case with far-reaching consequences (Post 4 of 4 “Gross Valuation Penalty Applies Irrespective of Value of Donated Property”), The Preserver, October 22, 2015

•Co-author, Bosque Canyon Ranch - conservation easement case with far-reaching consequences (Post 3 of 4 “The Baseline Documentation”), The Preserver, October 14, 2015

•Author, Land trusts should not be enlisted to police appraisals of valuation, The Preserver, July 8, 2015

•Author, Land trusts should not assume donations from syndicated partnerships are a problem, The Preserver, July 7, 2015

•Author, IRS applies CE type attacks in new bargain sale case, The Preserver, June 2, 2015

•Author, New Tax Court Conservation Easement case: Balsam Mountain Investments, LLC applying Belk, The Preserver, March 13, 2015

•Author, Favorable conservation easement bill passes: Rules for deductions extended, The Preserver, December 17, 2014

•Author, Correction of previous conservation easement article in The Preserver, The Preserver, December 16, 2014

•Author, Facade easement deduction denied where taxpayer promised to grant easements in exchange for assistance in seeking zoning variances from local planning board, The Preserver, November 13, 2014

•Author, Tax Court determines donors of facade easement are entitled to limited deduction; Appraisal and tax return 'substantially complied' with Treasury Regulations, The Preserver, November 6, 2014

•Author, The Tax Court in VisionMonitor Software, LLC, found common sense way to waive accuracy related penalties based on a reasonable reliance in a partnership context, The Defender, October 30, 2014

•Author, Tax court shoots down IRS's highest and best use argument in conservation easement case and refuses to impose penalties, The Preserver, May 8, 2014

•Author, Continued war of attrition on facade easements, The Preserver, March 21, 2014

•Author, Giving to a qualified organization is a key to conservation easement deduction, The Preserver, March 3, 2014

•Author, Conservation easement confusion in the Tax Court and the Fifth Circuit, The Preserver, September 3, 2013

•Author, Another Tax Court approach to establish highest and best use, The Preserver, August 6, 2013

•Author, Tax Court determines 'floating easement' is not a qualified real property interest, The Preserver, April 4, 2013

•Author, Appraisals and penalties: Lessons and advice from the Tax Court to Supreme Court, The Preserver, April 1, 2013

•Author, Tax law changes affecting conversation easements in The American Taxpayer Relief Act of 2012, The Preserver, January 2, 2013

•Author, Georgia passes bill creating major changes in the Georgia Conservation Tax Credit Act, The Preserver, April 10, 2012

•Author, Conservation easement valuation, The Preserver, June 17, 2010

•Author, Conservation easements: An effective land preservation tool, The Preserver, November 15, 2009

Editor, The Defender , Sirote's Tax Controversy Blog

•Author, “Notice 2018-006: How will the Government comply with Section 6751(b)?,” The Defender, June 28, 2018

•Author, Tax Court Slams IRS Penalty Argument: Penalties Abated Due to Reliance on CPA, The Defender, August 15, 2017

•Co-author, Real Estate Professionals - Substantiation and Logic Reign Supreme in Demonstrating Real Estate Professional Status, The Defender, May 8, 2017

•Co-author, In a Taxpayer Friendly Reasonable Compensation Case ...Independent Investor Test Explained, The Defender, May 18, 2016

•Co-author, Ninth Circuit Affirms Denial of Deduction of 'Management Fees' - Recordkeeping and Documentation of Services Provided Found Lacking, The Defender, March 2, 2016

•Author, IRS issues guidance that will help real estate professionals avoid passive activity loss rules, The Defender, July 8, 2014

•Author, IRS plays 'Gotcha' with the wrong Texas ranch family, but the Fifth Circuit rides to the rescue (in other words, 'Don't Mess with Texas'), The Defender, May 30, 2014

•Author, Will passive activity loss cases be the IRS's next favorite area to attack?, The Defender, May 5, 2014

•Author, Extension filing problems can cost your client big bucks: Rethinking Boyle in today's e-filing world, The Defender, February 25, 2014

•Author, You can't make this stuff up - Are parsonage allowances unconstitutional?, The Defender, December 20, 2013

•Author, Proposed form to report under new Section 1411, The Defender, October 15, 2013

•Author, Documenting loans by owners to their business is critical, The Defender, August 27, 2013

•Author, IRS 'unreasonable compensation' challenges likely to increase, The Defender, April 22, 2013

Corporate and Tax Planning

•Co-author, PSC Compensation (on the Brinks), Corporate and Tax Planning Today, March 2, 2016

•Co-author, Gridiron Alert: Ordinary income triggered in surprise upset of investment purpose, Corporate and Tax Planning, June 11, 2015

•Co-author, Taxpayers' evidence did not support real estate professional status, Corporate and Tax Planning, May 27, 2015

•Co-author, Taxpayers' material participation results in $5.2M refund in income taxes, Corporate and Tax Planning Today, May 27, 2015

•Author, Credible evidence is key to real estate professional exception under passive activity loss rules, Corporate and Tax Planning Today, January 21, 2015

•Author, Tax Court in McElroy v. CIR finds that Charitable Deduction on Contribution of Cemetery Lots Limited to Basis and that Section 165 Loss Treatment will not apply to Investors' Excess Basis, Corporate and Tax Planning Today, November 17, 2014

•Author, Tax Court holds that 'zeroing out' income through year-end bonus is ineffective because the C Corporation's bonus check not backed with sufficient funds, Corporate and Tax Planning Today, October 27, 2014

•Author, Tax Court in Aragona Trust impacts 469 and 1411 issues on material participation by trustee, Corporate and Tax Planning Today, March 28, 2014

•Author, Holding real estate as dealer and as investor: It is good to be an investor!, Corporate and Tax Planning Today, March 7, 2014

•Author, Tax Court and IRS making abandonments more difficult to prove, Corporate and Tax Planning Today, February 27, 2014

•Author, Will abandonment cause ordinary or capital loss?, Corporate and Tax Planning Today, December 17, 2013

•Author, New Section 1411: A maze of new rules, Corporate and Tax Planning Today, August 26, 2013

•Author, You may live abroad, but you still have to file at home, Corporate and Tax Planning Today, September 15, 2011

News

•Sirote Tax Attorney Ronald Levitt Presents “Section 199A and Its Impact on Choice Entity” at Several National Conferences
•Sirote Attorney Ronald Levitt to Speak at NYU’s Summer Institute in Taxation on July 26, 2018 on “Section 199A and its Application to S Corporations.”
•Sirote & Permutt Attorneys to Speak at 99th Alabama Society of CPAs Annual Meeting in Montgomery, Alabama, on June 14
•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
•Sirote & Permutt Announces 47 Attorneys Selected as The Best Lawyers in America for 2016
•Sirote & Permutt Presents Alabama Society of CPA Seminar Series
•Sirote & Permutt Announces 28 Attorneys Selected As Alabama Super Lawyers 2015
•Ronald Levitt to Speak at American Bar Association Tax Section Meeting
•Chris Bottcher Presents Lawyering Across Generations at the Association of Professional Responsibility Lawyers Conference
•Daily Tax Report Quotes Ronald Levitt
•Ronald Levitt Quoted in Two Bloomberg BNA Articles
•Sirote & Permutt's Ronald Levitt and David Wooldridge Quoted in Business Alabama Article on Kiva Dunes Case
•Sirote & Permutt Attorneys Included in The Best Lawyers in America for 2015
•Sirote & Permutt Presents ASCPA Webinar Series
•Sirote's Ronald Levitt to Speak About Conservation Easement
•Sirote & Permutt Attorneys to Speak at 95th Alabama Society of CPAs Annual Meeting
•Sirote's Tax Litigation Lawyers File Brief in Appeal of $2.1 Million Conservation Easement Deduction
•Sirote & Permutt Announces 28 Attorneys Selected As Alabama Super Lawyers 2014
•Sirote Attorneys Shirley Justice and Ronald Levitt To Lead Presentation On The Affordable Care Act's Tax Implications
•Alabama Society of Enrolled Agents Invites Sirote Attorneys to Speak About Health Care
•Ronald Levitt Speaks Nationally About Tax Issues
•Ronald Levitt and David Wooldridge Speak about Conservation Easements
•Attorneys Speak about Tax Issues to the Alabama Association of Accountants & Tax Preparers
•Sirote Attorneys Ronald Levitt and David Wooldridge to Serve as Panelists for the Land Trust Alliance
•Sirote Attorneys Ronald Levitt and Brad Sklar to Speak about LLC's at ASCPA Webinar
•Best Lawyers Recognizes 46 Sirote Attorneys as the Best Lawyers in America for 2014
•Sirote & Permutt Present ASCPA Hot Topics in Tax Webinar Series
•Sirote's Ronald Levitt Speaks About Environmental Capitalism and Investment Opportunities
•Sirote & Permutt Announces 30 Attorneys Selected as Alabama Super Lawyers 2013
•Sirote's Ronald Levitt Speaks about S-Corporations and LLC Mergers
•Sirote & Permutt Hosts a Free Seminar About Health Care Law
•Sirote's Ronald Levitt to Present Estate Planning Webinar
•Sirote's Ronald Levitt Warns of Looming Tax Issues for S Corporation Owners
•Ronald Levitt Offers Important 2013 Tax News for All Business Owners
•Sirote Legal Alert: The Changing Tax Climate
•Best Lawyers Recognizes 43 Attorneys from Sirote & Permutt as the Best Lawyers in America for 2013
•Register Now For Sirote-ASCPA Seminar Presented by Ronald Levitt
•Seminar for CPA, Banking, and Commercial Real Estate industries!
•Ronald Levitt Presenter for ASCPA Webinar
•Corporate, Tax and Estate Planning Attorneys Speak at ASCPA Annual Meeting
•Ronald Levitt Co-Author for LexisNexis Tax Planning Book
•Sirote & Permutt Lawyers in the Tax Press
•Sirote Attorneys Levitt and Wooldridge Elected to American College of Tax Counsel
•Sirote & Permutt Successfully Defends Case Against IRS
•Ronald Levitt to Moderate Panel at ABA Tax Section Meeting
•Ronald Levitt Speaks on Current Topics Affecting S-Corporations
•Six Sirote Attorneys Designated Best Lawyers of the Year for 2012
•Ronald Levitt and David Wooldridge to Present at Conservation Easement Conference
•Sirote Tax Attorneys Publish Land Easement Article
•Best Lawyers has selected 32 attorneys from Sirote & Permutt for recognition in The Best Lawyers in America for 2011
•Birmingham Magazine Names 5 From Sirote As Top Attorneys
•31 Sirote Attorneys Listed In Best Lawyers
•Sirote & Permutt Attorneys Have Successful Outcome In Landmark Conservation Easement Case Before US Tax Court
•Publication Recognizes 20 From Sirote As Super Lawyers
•Sirote Shareholder Levitt To Speak AT UNC Tax Institute
•Birmingham Magazine Recognizes 17 From Sirote As Top Attorneys

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

•Alabama State Bar
•Former Chair, Tax Section
•American Bar Association
•Council Director, Tax Section
•Former Chair, S Corporation Committee
•American Bar Foundation
•Alabama Fellow
•American College of Tax Counsel
•Former Member, Board of Regents
•Fellow
•Birmingham Tax Forum
•Former President
•Federal Tax Clinic
•Former President
•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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Birmingham, Alabama

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