Ronald A. Levitt

Ronald A. Levitt: Attorney with Sirote & Permutt, P.C.
  • Shareholder at Sirote & Permutt, P.C.
  • 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, Tax
•AV-Preeminent, Martindale-Hubbell Peer Review Rating

Professional Profile

Recognition

•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 2012 Tax Law Lawyer of the Year in Birmingham
•Mid-South Super Lawyers, Tax, 2008-2017
•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

Speeches & Publications

CONSERVATION EASEMENT

•Co-authored, “Tax Court Disallows Developer’s 11,040,000 Charitable Deduction: Characterizes PUD Plan Approval Process as Quid Pro Quo Arrangement. ” The Preserver-Conservation Easement blog, June 18, 2018
•Co-authored, “Confusion Following the Death of the Conservation Easement” Enhancement Regulation, ” The Preserver-Conservation Easement blog, April 11, 2018
•Co-authored, “Can RERI Holdings I, LLC Co-Existing Tax Court Precedent Regarding Conservation Easement Donations?” The Preserver-Conservation Easement blog, October 24, 2017
•Co-authored, “RERI Holdings I, LLC: What the Basis?” The Preserver-Conservation Easement blog, 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!” The Preserver-Conservation Easement blog, August 17, 2017
•Authored, “Notice 2018-006: How will the Government comply with Section 6751(b)? Greg Rhodes Quoted in MLex US Tax Watch Article, ” The Defender-Tax Controversy blog, June 28, 2018
•Speaker, 99th Alabama Society of CPAs Annual Meeting in Montgomery, Alabama, June 14, 2018
•Co-authored, “For Whom the Statute Tolls? The IRS.” The Preserver-Conservation Easement blog, June 5, 2017
•Speaker, American Bar Association’s Annual Tax Section May Meeting, Washington, DC, May 11, 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.” The Preserver-Conservation Easement blog, October 2, 2017
•Co-authored, “Listed Transaction Update: Hurricane Disaster Relief Does NOT Extend the October 2, 2017 Deadline to File IRS Form 8886, ” The Preserver-Conservation Easement blog, September 28, 2017
•Co-authored, “Conservation Easement Listed Transactions; New Notice 2017-29 (Or: The Good, The Bad and the Ugly-Sorry Clint Eastwood?),” The Preserver-Conservation Easement blog, April 28, 2017
•Co-authored, “Summa Holdings, Inc. pins the IRS in a rematch bout-Sixth Circuit counts IRS out.” The Preserver-Conservation Easement blog, February 24, 2017
•Speaker, “Land Conservation: The Worth of The Earth” 23rd Annual Public Interest Environmental Conference, February 10, 2017
•Co-authored, “Tax Court Upholds Penalty for Failure to Disclose a Listed Transaction Notwithstanding Eighth Amendment “Excessive Fine” Argument, ” The Preserver-Conservation Easement blog, February 6, 2017
•Co-authored, “Notice 2017-10 -- A Dirty Santa Gift Land Trusts and Others Don’t Want to Claim,” The Preserver-Conservation Easement blog,” January 19, 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,” The Preserver-Conservation Easement blog, May 10, 2016
•Authored, “US Senators Complain to IRS Commissioner About Over-Aggressive Audit Tactics in Audits of Conservation Easement Donations,” The Preserver-Conservation Easement blog, February 24, 2016
•Co-authored, “Eleventh Circuit Expounds on “Reasonable Probability” and “HBU” in Important Taxpayer-Favorable Opinion,” The Preserver-Conservation Easement blog, February 23, 2016
•Co-authored, “Pro Se Taxpayers in Facade Easement Case Doomed to Gross Valuation Penalty by Self-Inflicted Errors,” The Preserver-Conservation Easement blog, February 19, 2016
•Co-authored, “Easement Donors Find Themselves Without a “Legg: to Stand on in Penalty Case,” The Preserver-Conservation Easement blog, February 17, 2016
•Co-author, “Conservation Easement Confusion in the Tax Court and Fifth Circuit,” The Preserver-Conservation Easement blog and 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, “Simmons-Substantial Compliance Revisited”, Tax Notes, January 2010
•Co-author, “Kiva Dunes-Making and Substantiating the Value of Conservation Easements”, Journal of Taxation, November 2009

TAX

•Speaker, “Tax Cuts and Jobs Act of 2017: Developments for Business and Transactional Attorneys, ” 141st Alabama State Bar Annual Meeting & Legal Expo, Miramar Beach, Florida, June 29, 2018
•Speaker, CCIM Institute Webinar on “Capitalizing on Tax Reform,” April 4, 2018
•Co-authored, “Tax Court Slams IRS Penalty Argument: Penalties Abated Due to Reliance on CPA, ” The Defender-Tax Controversy blog, August 15, 2017
•Co-authored, “Real Estate Professionals-Substantiation and Logic Reign Supreme in Demonstrating Real Estate Professional Status, ” The Defender-Tax Controversy blo, May 8, 2017
•Speaker, The Florida Tax Institute on “Hot Topics for S Corporations,” Tampa, Florida, March 29-31, 2017
•Co-authored, “In A Taxpayer Friendly Reasonable Compensation Case. . . Independent Investor Test Explained,” The Defender-Tax Controversy blog, May 18, 2016
•Co-authored, “Ninth Circuit Affirms Denial of Deduction of “Management Fees”-Recordkeeping and Documentation of Services Provided Found Lacking, ” The Defender-Tax Controversy blog, 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
•Co-author, “Navigating the Defenses to Valuation Penalties in Charitable Deduction Cases,” Journal of Taxation, ” December 2014
•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, “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;
•Atlanta Tax Forum;
•Birmingham Tax Forum;
•Chattanooga Tax Practitioners;
•Florida Tax Institute;
•Great Lakes Federal Tax Institute;
•Heart of America Tax Conference;
•Land Trust Alliance Rallies;
•Oregon Tax Institute;
•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 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.” - 7/24/2018
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

A.G. Gaston Boys & Girls Club

Board of Directors, Former Member

Alabama State Bar

Tax Section, Former Chair

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 Regent

Birmingham Holocaust Education Center

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

Birmingham Tax Forum

Former President

Federal Tax Clinic

Former President

Helen Keller Foundation

Board of Directors

Leadership Birmingham

Class of 1996

Levite Jewish Community Center

President, 1995-1996

Board of Directors, Former Member

NCCJ (Local Chapter)

Board of Directors, Former Member

N.E. Miles Jewish Day School

Board of Directors, Former Member

Temple Beth-El

Vice President, 2016-present

Board of Directors

Temple Emanu-El

Vice President, 2006-2009

Board of Directors, Former Member

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

    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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    Documents (2)

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    Birmingham, Alabama

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