Charles M. Ruchelman

Charles M. Ruchelman: Attorney with Caplin & Drysdale, Chartered
  • Member at Caplin & Drysdale, Chartered (67 Attorneys)
  • One Thomas Circle NW, Suite 1100, Washington, DC 20005
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Biography

His strengths include the ability to speak about the law in layman's terms, strong follow-through, and an unbelievable attention to detail - Chambers USA

a great litigator, a good strategic thinker and an excellent advocate - Chambers USA

Mr. Ruchelman is a Member in Caplin & Drysdale's Washington, D.C., office, where he concentrates his practice in tax litigation and controversies with the Internal Revenue Service and other tax authorities. He also represents clients in general tax matters.

Services

Mr. Ruchelman has extensive experience in resolving tax matters at all stages of tax disputes including IRS examinations, IRS appeals, post-appeals mediation, trial court litigation, and appellate litigation. He has litigated cases in the U.S. Tax Court, various U.S. district courts, and the U.S. Court of Federal Claims.

Building on his experience with the TEFRA partnership provisions,
Mr. Ruchelman has spent a significant amount of time studying, speaking on, and writing about the new IRS tax and collection procedures relating to partnerships and limited liability companies that were recently enacted under the Bipartisan Budget Act of 2015. Since enactment of the new statute, Mr. Ruchelman has spoken on panels with a Tax Court judge, government officials from the Treasury Department and IRS Office of Chief Counsel, as well as other practitioners before the American Bar Association, American Institute of CPAs, DC Bar Association, and Bloomberg/BNA.

Government Experience

Attorney, U.S. Department of Justice, Tax Division, 1996-2003

Attorney, Internal Revenue Service, Office of Chief Counsel, 1993-1996

Government Experience

Before joining Caplin & Drysdale, Mr. Ruchelman was a Trial Attorney with the U.S. Department of Justice, Tax Division, and an Attorney with the Internal Revenue Service, Office of Chief Counsel.

While at the Department of Justice, he litigated tax cases in the federal district courts and the U.S. Court of Federal Claims. For his work representing the government in extended trials involving the IRS s attack on leveraged corporate-owned life insurance as a tax shelter, Mr. Ruchelman received the Attorney General s Distinguished Service Award.

Highlights

•Currently representing numerous clients in all stages of Internal Revenue Service examinations and Government investigations involving foreign accounts and foreign entities.
•Reached global settlement with IRS Office of Chief Counsel in 80 separate Tax Court cases involving common employee benefit plan tax issues.
•Represented third-party witness in Amazon.com Inc. & Subsidiaries transfer pricing case before the U.S. Tax Court.
•Represented a large Wall Street financial services firm in appeal to the 7th Circuit Court of Appeals (JPMorgan Chase & Co. v. C.I.R., 530 F.3d 634 (7th Cir. 2008)).
•Represented a hedge fund and its tax matters partner in a three-way IRS examination that led to litigation with the IRS and an adverse partner in the U.S. Court of Federal Claims (Imprimis Investors LLC v. United States, 83 Fed. CI. 46 (2008)).
•Successfully defended Hawaii Department of Taxation and its employees against unlawful disclosure claims in the U.S. District Court (Marsoun v. United States, 525 F. Supp.2d 206 (D. D.C. 2007)).
•Represented an international accounting firm in litigation concerning privilege issues (United States v. BDO Seidman LLP, 2004 WL 1470034 (N.D. Ill, June 28, 2004)).
•Represented a tax attorney in proceedings brought by the IRS Office of Professional Responsibility in the U.S. administrative court. IRS conceded significant issues on the eve of trial.
•Achieved a favorable settlement for a high-net-worth family in an IRS examination involving family limited partnership issues.
•Attained a favorable settlement for a high-net-worth individual in an IRS examination involving a contribution of a conservation easement.
•Successfully resolved an examination involving promoter penalty issues in IRS post-appeals mediation.

•Obtained a complete abatement and refund of over $600,000 of late filing, late payment, and late deposit penalties for multiple years for an oil services company relating to cross-border leasing payments and Form 1042.

•Successfully resolved expatriation case, reducing over $2,000,000 in proposed tax and over $400,000 of penalties to less than $75,000 in tax and no penalties.

Other Representative Matters

Mr. Ruchelman has represented clients before the IRS examination division, IRS Appeals, or in court involving the following substantive tax issues: IRS collections, family limited partnerships, contributions of conservation easements; estate and gift taxes, oil and gas partnerships, residency issues, restricted interest, employee benefits, and tax shelter disclosures. He also has considerable experience responding to IRS third-party summonses.

Blogs / Additional Resources

Partnership Representative
Captive Insurance

Awards & Rankings

Chambers USA, 2016-Present
The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2010, 2015-Present
The Legal 500, Leading Lawyer, 2011, 2012; Recommended, 2014
Super Lawyers, Washington, D.C., 2013-Present
The Washington Post, Top Attorneys in D.C., 2014

Recent Publications

• BLOG: IRS Publishes New Form 8981 and Form 8984, www.PartnershipRepresentative.com, March 19, 2019
• EXPERT ANALYSIS: Planning For Partnership Representatives In The New Year, with Rachel L. Partain and Aaron M. Esman, Law360, January 4, 2019
• BLOG: Tax Court Rules - Partnership Representative, with Benjamin Z. Eisenstat, www.PartnershipRepresentative.com, December 28, 2018
• BLOG: IRS Publishes Draft Instructions for Form 8979, Partnership Representative Revocation, Designation, and Resignation Form, with Aaron M. Esman, www.PartnershipRepresentative.com, December 5, 2018
• Year-End Updates on Partnership Representatives, with Rachel L. Partain and Aaron M. Esman, Caplin & Drysdale Client Alert, November 6, 2018
• Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets, with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Arielle M. Borsos, Caplin & Drysdale Client Alert, November 6, 2017
• Captive Insurance: State Reporting Obligations for Transactions of Interest, with Christopher S. Rizek and Rachel L. Partain, International Law Office, March 3, 2017
• IRS Launches Issue Based Corporate Compliance Campaigns, with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Global Tax Weekly, February 16, 2017
• Captive Insurance Industry Should Be Aware of State Reporting Obligations for Transactions of Interest, with Christopher S. Rizek and Rachel L. Partain, Caplin & Drysdale Client Alert, February 10, 2017
• IRS Launches 13 Issue-Based Corporate Compliance Campaigns, with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Caplin & Drysdale Client Alert, February 3, 2017
• Syndicated Conservation Easement Transactions Identified as New 'Listed Transactions', with Christopher S. Rizek, International Law Office, January 27, 2017
• Tax Claims - Court of Federal Claims: Jurisdiction, Practice, and Procedure, Court of Federal Claims: Jurisdiction, Practice, and Procedure, January 9, 2017
• Congress Looks to Fix New Partnership Audit Rules, with Elizabeth J. Stevens, Jonathan S. Brenner, and Rachel L. Partain, International Law Office, January 6, 2017
• Syndicated Conservation Easement Transactions Identified as New Listed Transactions , with Christopher S. Rizek, Caplin & Drysdale Client Alert, January 3, 2017
• Congress Looks to Fix New Partnership Audit Rules, with Jonathan S. Brenner, Rachel L. Partain, and Elizabeth J. Stevens, Caplin & Drysdale Client Alert, December 14, 2016
• Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, with Rachel L. Partain, Mark D. Allison, and Christopher S. Rizek, International Law Office, November 25, 2016
• Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, with Rachel L. Partain, Mark D. Allison, and Christopher S. Rizek, Caplin & Drysdale Client Alert, November 3, 2016
• IRS Issues First Partnership Audit Regulations, Caplin & Drysdale Client Alert, August 8, 2016
• IRS Seeks Comments for New Tax Examination and Collection Regime, International Law Office, April 8, 2016
• US Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships and LLCs, Family Office Elite Magazine, April 1, 2016
• IRS Seeks Comments to Promulgate Regulations for New Tax Examination and Collection Regime for Partnerships and LLCs, Caplin & Drysdale Client Alert, March 18, 2016
• Congress Enacts New Tax Examination and Collection Regime for Partnerships, with Christopher S. Rizek, Mark D. Allison, and Rachel L. Partain, International Law Office, January 22, 2016
• Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships, with Christopher S. Rizek, Mark D. Allison, and Rachel L. Partain, Caplin & Drysdale Client Alert, December 10, 2015
• New Law Changes FBAR Filing Deadline, with Zhanna A. Ziering, Mark D. Allison, Niles A. Elber, and Mark E. Matthews, Caplin & Drysdale Client Alert, August 10, 2015
Moore Requires 'More' Scrutiny of IRS-Imposed FBAR Penalties Under the Administrative Procedures Act, Family Office Elite Magazine, July 17, 2015
• Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List, with Rachel L. Partain, Mark D. Allison, and Christopher S. Rizek, International Law Office, February 27, 2015
• Abusive Small Captive Insurance Companies Added to IRS Dirty Dozen Tax Scams , with Rachel L. Partain, Mark D. Allison, and Christopher S. Rizek, Caplin & Drysdale Client Alert, February 13, 2015
• Enforcing Non-U.S. Tax Authority Requests for Taxpayer Information, with Arielle M. Borsos, International Law Office, March 7, 2014
• Washington Tax Roundup, Washington Jewish Week, January 8, 2014
• Jurisdictional Uncertainty in Trust Fund Recovery Penalty Cases, Tax Notes, p. 963, December 16, 2013
• Global Netting: Potential Opportunities for Corporate Taxpayers, with James E. Salles, WTE Practical International Tax Strategies, Volume 17, Number 8, April 30, 2013
• Global Netting: Potential Opportunities for Corporate Taxpayers, with James E. Salles, Caplin & Drysdale Client Alert, April 10, 2013
• LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties, with Mark D. Allison and Christopher S. Rizek, Caplin & Drysdale Client Alert, July 29, 2011
• Once Again Employment Tax Compliance at the Forefront of IRS's Enforcement Agenda, Bloomberg Law Reports, June 21, 2010
• Kiva Dunes and Golf Course Conservation Easements: Important Implications for Tax Deductibility of Conservation Easement Contributions, with Matthew C. Hicks, Free State Accountant, January 1, 2010
• A $200,000 Penalty for a $25,000 Deduction??!!: the High Price of Failing to Disclose Listed Transactions Under Section 6707A of the Code, November 7, 2008
• Conservation Easements Under Fire: A Five-Point Strategy to Defend the Deduction, Maryland Society of Accountants: The Free State Accountant, June 1, 2008

Recent Speaking Engagements

•Panelist, Captive Legal and Tax Insights, Kentucky Captive Association, 2017 Kentucky Captive Association Educational Conference, June 16, 2017
•Panelist, TOIs, Investigations, and Campaigns - the Tools of the IRS, Delaware Captive Insurance Association Spring Forum, May 8, 2017
•Panelist, Part 5 of 6 Pass-Throughs and Real Estate and Part 6 of 7 Tax Audits and Litigation Tax Series: Exploring the Proposed BBA Partnership Audit Regulations, D.C. Bar, April 5, 2017
•Speaker, Captive Insurance: New IRS Tax Reporting Regime, AICPA, December 19, 2016
•Speaker, Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, Bloomberg BNA, December 9, 2016
•Speaker, Small Captive Insurers and the New IRS Reporting Regime, Delaware Captive Insurance Association, December 1, 2016
•Moderator, Fundamental Partnership Audit Reform, Part 2 - What's a Practitioner to Do?, District of Columbia Bar, Taxation Section, June 23, 2016
•Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships, American Institute of CPAs, May 16, 2016
•Moderator, Litigating Partnership Tax Cases Under the New Partnership Tax Rules of the Bipartisan Budget Act of 2015, American Bar Association Section of Taxation, May 6, 2016
•Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships: Understanding the Nuances of the New Legislation, Bloomberg BNA, April 21, 2016
•Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships, District of Columbia Bar, February 2, 2016
•Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships, Bloomberg BNA, January 26, 2016
•Panelist, IRS Summons Update - Trends and Recent Developments in the Use and Enforcement of IRS Summonses, District of Columbia Bar, Tax Audits and Litigation Tax Series, December 12, 2013
•Speaker, Ins and Outs of IRS Audits of Partnerships and S Corps, University of Virginia, School of Law, 65th Annual Virginia Conference on Federal Taxation, June 7, 2013
•Moderator, The Outer Limits of Tax Jurisdiction in the U.S. Court of Federal Claims, Court of Federal Claims Bar Association and Caplin & Drysdale, April 23, 2013
•Panelist, Global High Wealth Industry Group Examinations, District of Columbia Bar, Tax Audits and Litigation Tax Committee, February 26, 2013
•Presenter, Bank of New York v. Commissioner Case, Federal Bar Association, Practice and Procedure Discussion Group, February 25, 2013
•Panelist, Tax Court Law Clerk CLE Presentation, U.S. Tax Court CLE Program, December 11, 2012
•Speaker, Resolving IRS Tax Controversies, How to Prepare for Audits and Appeals, Resolve IRS Disputes, Mitigate Penalties and Understand Alternative Dispute Resolution Methods, Bloomberg BNA, June 13, 2011
•Moderator, Common Evidentiary Issues in Tax Cases, American Bar Association, 2011 May Meeting, May 6, 2011
•Moderator, When, Where, and How, District of Columbia Bar, The Employment Tax National Research Program, May 27, 2010
•Moderator, Shelter Controversies: Penalties and Recent Developments, Federal Bar Association, 34th Annual Tax Law Conference, March 5, 2010
•Panelist, Stipulations in the Tax Court, American Bar Association, 2010 Midyear Meeting, January 22, 2010
•Litigating for the IRS: How It's Done and Where It Leads, November 20, 2009
•FOIA - It Doesn't Hurt (And May Help) To Ask, September 24, 2009
•Codification of Economic Substance: Its Potential Impact on Audits and Litigation, May 17, 2007
•Spotlight on Procedure: Privilege Claims Relating to Email Chains, January 19, 2007
•The Intersection of FOIA and Tax Litigation with Emphasis on New Chief Counsel Notice 2006-16, October 12, 2006

Recent News

•Charles Ruchelman Discusses Second Quarter 2018 Cases with Bloomberg BNA, Bloomberg BNA, July 5, 2018
Chambers USA Recognizes 10 Caplin & Drysdale Lawyers as Leaders in Their Fields, Chambers USA, May 3, 2018
•18 Caplin & Drysdale Attorneys Recognized by Super Lawyers in D.C., April 23, 2018
•Charles Ruchelman Comments on Proposed IRS Changes Likely to Increase Access to Appeals, Daily Tax Report, March 28, 2018
•Charles Ruchelman Comments on IRS Chief Counsel Nomination, Law360, March 2, 2018
•Caplin & Drysdale Lawyers Improve Their 2017 Chambers' Rankings, Chambers USA, June 2, 2017
•Law360 Speaks to Charles Ruchelman on New Liabilities for Partnership Reps, Law360, May 17, 2017
•Charles Ruchelman Discusses Micro-Captive Transaction Disclosures with Accounting Today, Accounting Today, May 5, 2017
•Caplin & Drysdale Lawyers Listed Among D.C.'s Most Prominent Practitioners, Super Lawyers, April 27, 2017
•Charles Ruchelman Discusses FBAR Filing and Deadlines with Daily Tax Report, Daily Tax Report, April 14, 2017
•Arielle Borsos and Charles Ruchelman Comment on Dutch Request for John Doe Summonses, Tax Notes, April 6, 2017
•Mark Allison and Charles Ruchelman Comment: Record-Low Audit Rates Could Reverse as IRS Alters Exams, Bloomberg BNA, February 27, 2017
•Charles Ruchelman Discusses Partnership Audit Rule Freeze Causing Confusion For States, Law360, February 17, 2017
•Daily Tax Report Quotes Charles Ruchelman: IRS Revving Up Efforts to Find Partners Who Owe Tax, Daily Tax Report, February 7, 2017
•Charles Ruchelman Comments on Montana CPAs Opposing Partnership Audit Legislation, Bloomberg BNA's Tax Management Weekly State Tax Report , January 27, 2017
•IRS Proposed Partnership Audit Rules Withdrawn from OFR, www.PartnershipRepresentative.com, January 26, 2017
•Caplin & Drysdale Tax Lawyer Charles Ruchelman Launches Website on New Partnership Audit Rules, Caplin & Drysdale, January 24, 2017
•MEDIA ADVISORY: Deadline for Small Captive Insurance Company Filing is January 30, 2017, Caplin & Drysdale, Chartered, November 17, 2016
•AICPA Offers Comments/Recommendations to New Partnership Audit Regime, www.partnershiprepresentative.com, October 12, 2016
•Bloomberg Quotes Charles Ruchelman: Partnerships Up a Creek Without a Pushout in JCT Analysis, Bloomberg BNA Daily Tax Report, October 7, 2016
•IRS Writing Partnership Audit Guidance Based on Present Law, www.partnershiprepresentative.com, October 7, 2016
•Partnership Audit Regime Proposed Regs Expected Soon, www.partnershiprepresentative.com, September 30, 2016
•Daily Tax Report Quotes Charles Ruchelman on Pending Separation of Powers Act and Its Impact on Proposed Debt-Equity Regulations, Daily Tax Report, July 25, 2016
•Caplin & Drysdale Listed Among Top Lawyers for Tax, Bankruptcy, Estate Planning and Political Law, Chambers USA, June 1, 2016
•Tax Notes Quotes Charles Ruchelman on New Regulations Concerning Listed Transactions, Tax Notes, April 28, 2016
•Super Lawyers Recognizes Caplin & Drysdale Lawyers from Several Practice Areas, Super Lawyers, April 26, 2016
•Bloomberg BNA Quotes Charles Ruchelman on New Partnership Examination and Collection Laws, Bloomberg BNA, April 22, 2016
•Daily Tax Report Quotes Charles Ruchelman on Including FBAR Penalties in Whistle-Blower Rewards, Daily Tax Report, March 16, 2016
•BNA Bloomberg Daily Tax Report Quotes Charles Ruchelman on Treasury/FinCEN's Proposed FBAR Regulation, Daily Tax Report, March 3, 2016
•Bloomberg BNA Quotes Charles Ruchelman on New Partnership Tax Examination and Collection Statute, Bloomberg BNA, February 3, 2016
•Tax Notes Quotes Charles Ruchelman on New Tax Laws for Partnerships at D.C. Bar Panel, Tax Notes Today, February 3, 2016
•U.S. Court of Appeals Rules in Favor of Pro-Israel Organization in IRS Discriminatory Israel Special Policy Case, Caplin & Drysdale, June 23, 2015
•Law360 Quotes Charles Ruchelman on IRS Hiring Outside Litigators, Law360, June 18, 2015
•Caplin & Drysdale Named Top Tier Firm for Tax Controversy, June 8, 2015
•Super Lawyers Lists Caplin & Drysdale Lawyers, Caplin & Drysdale, April 23, 2015
•Charles Ruchelman Comments on How Moore Answers Novel FBAR Questions, Tax Notes Today, April 14, 2015
•Charles Ruchelman Comments on IRS Unprecedented Hiring of Private Law Firm, Law360, April 6, 2015
•Daily Tax Report Quotes Charles Ruchelman on IRS Aiming to Audit C Corporations, Large Partnerships at Similar Rates, Daily Tax Report, February 26, 2015
•The Washington Post Lists Caplin & Drysdale Attorneys Among the Top Attorneys in D.C., The Washington Post, April 30, 2014
•Charles Ruchelman Comments on Americans in Israel Targeted by IRS Tax Audits, The Jewish Daily Forward, March 3, 2014
•Forbes Quotes Charles Ruchelman: Appellate Court Delivers Blow to IRS and Taxpayers, Nixing Tax Return Preparer Regs, Forbes, February 11, 2014
•Charles Ruchelman Comments on Israeli Bank Disclosures, February 3, 2014
•JNS.org Quotes Charles Ruchelman: Americans with Israeli Bank Accounts Could Face Troubling Tax Season, JNS.org, January 13, 2014
•Swiss Banks Forced to Disclose Foreign Accounts and Transfers to U.S. Authorities, Caplin & Drysdale, December 19, 2013
•Bloomberg Quotes Charles Ruchelman: IRS Will Move Quickly to Summonses Under New Document Request Procedures, Bloomberg, December 12, 2013
•Forbes Quotes Charles Ruchelman: Supreme Court Sides With IRS In Tax Shelter Penalty Case, Forbes, December 3, 2013
•Washington Jewish Week Quotes Charles Ruchelman on IRS Scrutiny of U.S. Citizens' Bank Accounts in Israel, Washington Jewish Week, June 28, 2013
•CNBC Speaks to Charles Ruchelman About the Surge in IRS Audits of the Wealthy, CNBC, May 13, 2013
•Wealthy Americans Target of New IRS Initiative, Caplin & Drysdale, May 7, 2013
•Super Lawyers Lists Nineteen Caplin & Drysdale Attorneys, Super Lawyers, April 29, 2013
•Tax Notes Quotes Charles Ruchelman on COFC Program Hosted by Caplin & Drysdale, Tax Notes, April 24, 2013
•The Jewish Chronicle Quotes Charles Ruchelman on IRS' Probe of Israeli Bank Account Holders, The Jewish Chronicle, March 5, 2013
•The Jewish Observer Quotes Charles Ruchelman on Americans with Israeli Bank Accounts, The Jewish Observer, Los Angeles, March 3, 2013
•VIN News Quotes Charles Ruchelman Concerning IRS Crackdown on Israeli Bank Accounts, VIN News, February 22, 2013
•Chambers and Legal 500 Recognize Caplin & Drysdale in 2012 Top Rankings, Chambers USA / The Legal 500, June 12, 2012
•Chambers and Legal 500 Recognize Caplin & Drysdale in 2011 Top Rankings, Chambers USA / The Legal 500, June 16, 2011
•Charles Ruchelman Comments on the IRS's Aggressive Audits of Easements, Dow Jones, March 15, 2011

Areas of Practice (2)

  • Tax Controversies
  • Tax Litigation

Education & Credentials

Contact Information:
(202) 862-7834  Phone
www.caplindrysdale.com
University Attended:
George Mason University, B.S., with distinction, 1990
Law School Attended:
Syracuse University College of Law, J.D., cum laude, 1993; Georgetown University Law Center, LL.M., Taxation, 1999
Year of First Admission:
1994
Admission:
U.S. District Court for the District of Columbia; U.S. Court of Appeals for the Federal Circuit; District of Columbia Court of Appeals; U.S. District Court for the Southern District of New York; U.S. Court of Appeals for the Seventh Circuit; U.S. Bankruptcy Court for the District of Columbia; U.S. Tax Court; U.S. Court of Federal Claims; 1994, New York; 2004, District of Columbia
Memberships:

Other Professional Affiliations

Past Chair, District of Columbia Bar, Section onTaxation, Tax Audits and Litigation Committee

Member, American Bar Association, Section of Taxation

Member, U.S. Tax Court's J. Edgar Murdock Inn of Court

Professional Activities

Mr. Ruchelman recently completed his tenure as Chairman of the Tax Audits and Litigation Committee for the Tax Section of the D.C. Bar. This committee presented monthly panel discussions on hot topics in the tax audits and litigation arena and frequently interacted with IRS and DOJ tax officials. He is also an active member of the American Bar Association Section of Taxation, the Court of Federal Claims Bar Association, and the U.S. Tax Court's J. Edgar Murdoch Inns of Court.

Reported Cases:
Other Representative Matters; Mr. Ruchelman has represented clients before the IRS examination division, IRS Appeals, or in court involving the following substantive tax issues: IRS collections, family limited partnerships, contributions of conservation easements; estate and gift taxes, oil and gas partnerships, residency issues, restricted interest, employee benefits, and tax shelter disclosures. He also has considerable experience responding to IRS third-party summonses.
ISLN:
910432908

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Washington, District of Columbia

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