Michelle Abroms Levin

Michelle Abroms Levin: Attorney with Sirote & Permutt, P.C.
  • Of Counsel at Sirote & Permutt, P.C. (112 Attorneys)
  • 305 Church Street, Suite 800, Huntsville, AL 35801
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Biography

Michelle is a member of the firm’s Tax Controversy and Litigation Department, part of the Tax Practice Group . She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, and federal district court. Her experience includes a wide range of complex tax issues. Prior to joining Sirote, Michelle worked as a trial attorney at the Tax Division of the Department of Justice where she represented the United States in federal district court.

Why did you become an attorney?

I loved the challenge of it; the complexity. I love doing work that matters to people.

What is the best part of your job?

We are problem solvers. The matters we handle are often extremely complex with layers of issues. It is a great feeling when you are able to resolve a thorny issue and achieve a great result for your client. Those are the days you work for.

Thought Leadership

•Represents clients during all phases of federal tax controversies, including IRS audit, administrative appeals, and court proceedings in the United States Tax Court, United States Court of Federal Claims, and federal district court

•Experience includes a wide range of complex tax issues, including economic substance and business purpose, partnership issues, OID, transfer pricing, accuracy-related penalties, foreign tax credits, and criminal tax issues

•Extensive knowledge of subjects related to federal tax practice and procedure and the handling of tax controversies and litigation

•Previously worked as a trial attorney at the Tax Division of the Department of Justice, representing the United States in federal district courts in Alabama, Georgia, and Florida, in a wide variety of tax cases, including refund, bankruptcy, and preparer-injunction cases

Speeches and Publications

•Author, The Defender , Sirote's Tax Controversy Blog

•Co-author, Navigating the Defenses to Valuation Penalties in Charitable Deduction Cases, Journal of Taxation, December 2014

•Author, Avoiding IRS Penalties: Who Can You Rely On?, The Counselor, September 2013

News

•Sirote & Permutt Presents Alabama Society of CPA Seminar Series
•Sirote's Tax Litigation Lawyers File Brief in Appeal of $2.1 Million Conservation Easement Deduction
•Sirote & Permutt Hires Tax Attorney in Huntsville Office

Areas of Practice (9)

  • Alternative Dispute Resolution
  • Government Contracts
  • Litigation
  • Tax
  • Conservation Easements
  • Criminal Law
  • Trust & Estate Litigation
  • Tax Controversy & Litigation
  • White Collar Investigations & Defense

Education & Credentials

Contact Information:
Mailing Address:
P.O. Box 18248, Huntsville, AL 35801
University Attended:
Washington University, Olin School of Business, B.S.B.A., magna cum laude, William S. Krebs Accounting Award, 2002
Law School Attended:
University of Texas School of Law, J.D., Texas International Law Journal, Staff Editor, James A. Elkins Memorial Scholarship, 2005
Year of First Admission:
2005
Admission:
U.S. Court of Federal Claims; U.S. Tax Court; 2013, Alabama; 2005, Georgia; 2007, District of Columbia
Memberships:

Organizations

•Admitted to practice
•United States Court of Federal Claims
•United States Tax Court
•Alabama State Bar
•The District of Columbia Bar

Reported Cases:
Recent Matters: GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner, U.S.Tax Court Docket Nos. 18940-08 and 18941-08 (decision entered Oct. 4, 2010.) (Debt/equity, OID case fully conceded by IRS); Fidelity International Currency Advisor A Fund, L.L.C. v. United States, No. 05-40151 & 06-40130 (D. Mass.); Fidelity High Tech Advisor A Fund, L.L.C. v. United States, Nos. 06-4-243 & 06-40244 (D. Mass.) (45-day trial on variety of issues including economic substance, TEFRA and tax treatment of contingent obligations)
ISLN:
920951994

Peer Reviews

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Huntsville, Alabama

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