I specialize in estate and tax planning, commercial transactions and taxpayer representation..

Estate Planning:

My estate planning clients are limited to those with potentially taxable estates.  I tend to have a relatively aggressive approach to minimizing potential estate tax liabilities.

A typical estate plan involves tax planning and documentation.  Tax planning often involves titling assets for valuation discounts and gifting techniques to freeze values for tax purposes without losing control.  The documentation would normally include a pourover will, revocable living trust, irrevocable (e.g., insurance) trusts as well as a family limited liability company.   Other techniques often employed include qualified personal residence trusts (QPRT’s), grantor retained annuity trusts (GRAT’s), private annuities; and gifts to inter vivos irrevocable trusts with extensive use of "Crummey" letters.   

In addition, I provide post-death services such as probating wills, trust administration and preparing estate tax returns.

Commercial Transactions:

I form many corporations, LLC’s and LLP’s. I also advise and draft documents in connection with reorganizations, merger and acquisition transactions, stockholder, partnership and employment agreements, like-kind exchanges and startup ventures.  But my favorite work is minimizimg taxes via creative planning.  

Taxpayer Representation:

I represent taxpayers before the IRS with respect to audit, administrative appeals, collection and (occasionally) criminal tax matters. I also litigate against the IRS in the United States Tax Court. Similar services are provided to clients with state tax problems.

I also represent taxpayers before the IRS in obtaining exemptions for charitable entities. While I have experience with respect to drafting and administering retirement plans, I refer such matters whenever similar services are available for a lower fee (which is usually the case.)

I do not prepare income tax returns.