Sullivan
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Biography

  • Provided tax structuring advice on the recapitalization of an art storage business that relocated into an Opportunity Zone
  • Represented an international distributor of electronic components in a dispute with the Massachusetts Department of Revenue over whether the corporation and its wholly-owned subsidiary conducted a unitary business
  • Negotiated a full concession by the IRS of a proposed $10 million tax assessment and civil fraud penalties against an individual taxpayer
  • Secured a multi-million dollar refund of Massachusetts insurance premium excise following a trial before the Massachusetts Appellate Tax Board, and successfully argued an appeal of the decision before the Massachusetts Supreme Judicial Court
  • Secured a multi-million dollar refund of a Massachusetts utility corporation excise for the owner of a power plant
  • Represented an individual on trial for federal tax crimes
  • Represented individuals and corporations in litigation involving the IRS before the United States Tax Court and United States District Court
  • Represented clients during IRS audits and at the IRS Office of Appeals on matters involving partnership taxation, estate and gift tax, and individual and corporate income tax
  • Provided assistance to clients in controversies involving the Massachusetts Department of Revenue at the administrative level and before the Appellate Tax Board, including individual domicile audits and other income tax issues, as well as matters involving corporate excise and sales and use taxes

Matters

  • Provided tax structuring advice on the recapitalization of an art storage business that relocated into an Opportunity Zone
  • Represented an international distributor of electronic components in a dispute with the Massachusetts Department of Revenue over whether the corporation and its wholly-owned subsidiary conducted a unitary business
  • Negotiated a full concession by the IRS of a proposed $10 million tax assessment and civil fraud penalties against an individual taxpayer
  • Secured a multi-million dollar refund of Massachusetts insurance premium excise following a trial before the Massachusetts Appellate Tax Board, and successfully argued an appeal of the decision before the Massachusetts Supreme Judicial Court
  • Secured a multi-million dollar refund of a Massachusetts utility corporation excise for the owner of a power plant
  • Represented an individual on trial for federal tax crimes
  • Represented individuals and corporations in litigation involving the IRS before the United States Tax Court and United States District Court
  • Represented clients during IRS audits and at the IRS Office of Appeals on matters involving partnership taxation, estate and gift tax, and individual and corporate income tax
  • Provided assistance to clients in controversies involving the Massachusetts Department of Revenue at the administrative level and before the Appellate Tax Board, including individual domicile audits and other income tax issues, as well as matters involving corporate excise and sales and use taxes

Matters

Matters