Representative Experience
Forms corporations, limited liability companies, partnerships and joint venture business entities

Acquires and disposes of businesses in taxable and tax-deferred transactions

Structures and documents contractual arrangements (e.g., employment agreements, executive deferred compensation agreements, restricted stock agreements, stock option plans, etc.)

Handles tax dispute resolution/litigation matters involving the Internal Revenue Service and the Oregon Department of Revenue, including disputes involving the valuation of assets such as land, operating businesses (e.g., commercial nurseries, medical practices, etc.), patents, standing timber, etc.; excise taxes relating to trucks, specialty trailer bodies, and sport fishing equipment; the appropriate compensation of corporate officers; the excessive retention of corporate earnings; the apportionment of income among states; and TEFRA partnerships

Representative Cases Litigated
Cascade Designs, Inc. v. Commissioner, T. C. Memo 2000-58

U.S. Bancorp and Subsidiaries v. Dept. of Revenue, 13 O.T.R. 84 (1994)

Hudspeth et al., v. Commissioner, T.C. Memo 1985-628

Hokanson v. Commisioner, T.C. Memo 1982-414, aff’d 730 F.2d 1245 (9th Cir. 1984)

Worley v. Commissioner, T.C. Memo 1980-51

Estate of Clara Edgar v. Commissioner, 74 T.C. 983 (1980), aff’d mem., 676 F.2d 685 (3rd Cir. 1982)

Prior Experience
Trial attorney for the Office of District Counsel, Internal Revenue Service

Publications and Presentations
Assists numerous nonprofit organizations by conducting probate, estate planning, and planned giving seminars

Co-author, "Tax-Exempt Organizations," Chapter 29, Oregon Health Law Manual

Memberships and Activities
Oregon State Bar

Member, Business Law and Taxation sections, Oregon State Bar

Selected to "Oregon Super Lawyers," Law & Politics, 2007

Education
J.D., Gonzaga University School of Law

B.S., University of Pittsburgh