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Sullivan's Tax Group provides time-is-of-the-essence, state-of-the-art, partner-level advice on a wide range of complex tax issues. Our tax partners creatively address the entire spectrum of tax-related legal matters, from tax planning for sophisticated corporate reorganizations to the representation of clients in adversarial proceedings with the Internal Revenue Service and state tax authorities.

Regardless of the context or forum, our Tax Group identifies each client’s objectives and then designs efficient and cost-effective strategies for achieving them. We solve complex problems across a wide range of tax regimes for a wide range of clients, including:

  • International, federal and state tax planning
  • Tax planning for business owners, investors and high-net-worth individuals (HNWI)
  • Tax planning for mutual funds, REITs and other pooled investment vehicles
  • Tax planning for public charities and private foundations
  • Tax planning related to employee benefits and executive compensation plans
  • Public company tax compliance and representation
  • Representation in federal and state tax controversies, including administrative appeals and all phases of litigation

Clients

We serve corporate and individual taxpayers across a wide variety of industries throughout the United States. Our international work is often a result of our connections with other professionals around the world.

Many of our clients reflect our depth in the real estate, private equity, and financial services sectors. Our size and national reputation demonstrate our commitment to quality, an ability to design creative solutions to complex problems and the insight to understand and achieve our clients' goals.

Representative Client Work

  • Provide strategic guidance on corporate tax issues, including reorganizations, tax treatment of net operating losses, real estate transactions, cross-border transactions and the tax problems of closely-held businesses and their owners
  • Develop estate planning strategies for the tax-efficient transfer of wealth to the next generation
  • Conform the structure of employee benefits, equity incentives, executive compensation and retirement planning to all applicable tax requirements
  • Resolve controversies with federal and state tax authorities
  • Structure charitable giving and charitable foundations and trusts for maximum tax advantage, and offer guidance to tax-exempt entities
  • Ensure maximum tax advantage in the structure and operation of hedge funds, private securities partnerships, LBO and venture capital funds, regulated investment companies, real estate investment trusts and foreign corporations

Client Highlights
All Client Highlights
Nonprofit Network Drives Skills-First Movement for a More Equitable and Inclusive Future Workforce
Sullivan acts as outside general counsel for Skillsright, Inc., a nonprofit coalition of the country’s top employers and their CEOs with a mission of driving a skills-first movement to unlock career opportunities for talent without four-year degrees, for a more equitable and inclusive future workforce. Sullivan handles a wide range of matters including obtaining the organization’s nonprofit (Internal Revenue Code Section 501(c)(3)) status, advising on a variety of legal issues associated with the organization’s work, negotiating intellectual property rights, drafting employment offers and dealing with related employment and benefits issues, overseeing all contracting issues and advising on corporate governance.
Admiral Metals Acquired by Reliance Steel & Aluminum Co., Largest Metals Service Center Company in North America
Sullivan represented Admiral Metals who was acquired by Reliance Steel & Aluminium Co. (NYSE: RS). “Admiral Metals has built a strong reputation in the metals industry for providing specialty products, high levels of customer service and next-day delivery,” commented Jim Hoffman, Chief Executive Officer of Reliance. “We believe this acquisition will enable Admiral Metals to leverage Reliance’s scale in order to capitalize on further growth opportunities while maintaining its strong brand recognition. We are excited to welcome Admiral Metals to the Reliance Family of Companies, our 70th acquisition since our 1994 IPO.”
Viewpoints
All Viewpoints
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert focuses on the impact of the Housing Act on institutional investor ownership of single-family rental homes.  The Housing Act does not prohibit institutional investor ownership of manufactured homes. The section of the Housing Act impacting institutional investor ownership of single-family rental homes is Section 1001 (the Section is titled “Homes Are for People, Not Corporations”).  The primary impacts under Section 1001 are (i) a prohibition on purchases of single-family homes (with important exceptions) and (ii) the creation of a “Renter Outreach Resource” managed by the federal government.  Section 1001 uses a number of defined terms, which are summarized in Appendix A to this alert.  The defined terms are indicated in this alert in italics.  The most important – and most extensive – defined term is excepted purchase, which includes, among other programs, purchases of single-family homes pursuant to build-to-rent programs and purchases of single-family homes from other large institutional investors. No Requirement to Dispose When the U.S. Senate passed a version of the Housing Act in March 2026, the legislation included a controversial, perhaps even unconstitutional, provision requiring institutional investors to dispose of certain single-family homes not later than seven years after the date of purchase.  A relief to such institutional investors, the Housing Act, as enacted, does not include that requirement to dispose. Prohibition on Purchases (with Several Exceptions) The Housing Act prohibits the purchase of single-family homes by large institutional investors, excluding any excepted purchase or any purchase of a single-family home in connection with a restructuring or other reorganization of ownership of single-family homes that were owned or purchased on or before the date of enactment of the Housing Act.  The prohibition on purchases takes effect on January 7, 2027 (180 days after the date of enactment of the Housing Act) (the “Effective Date”) and is repealed on January 7, 2042 (15 years after the Effective Date). Excepted purchases (i.e., those not prohibited) are described in detail in Appendix A under the defined term “Excepted Purchase”, but generally include many of the common methods by which institutional investors in single-family rental homes acquire such homes, including but not limited to: (i) build‑to‑rent programs, (ii) renovate‑to‑rent programs, (iii) repossessions, (iv) foreclosures, (v) purchases from another large institutional investor, or (vi) combinations of (i) through (v). Enforcement of Prohibition on Purchases The Secretary of the Treasury, or the Attorney General at the request of the Secretary of the Treasury, may bring an action against a large institutional investor that violates the prohibition on purchases for a civil penalty in an amount that is not more than $1,000,000 per violation, or three times the purchase price of the property involved, whichever is greater. Renter Outreach Resource As described in detail below, the Renter Outreach Resource is a comprehensive program that includes direct reporting of rental disputes by renters to Federal agencies, with investigation and reporting requirements imposed on applicable Federal agencies, and (at a minimum) provision of applicable state agency contact information to renters to facilitate state-level investigation.  In addition, large institutional investors must respond to information requests in connection with any investigation and are required to regularly provide certain information regarding the Renter Outreach Resource to their renters. Establishment of Renter Outreach Resource The Secretary of Housing and Urban Development (the “HUD Secretary”) is required, not later than 180 days after the date of enactment of the Housing Act, to establish the Renter Outreach Resource that consists of a toll-free telephone number and a public website designed to assist renters of residential properties owned by a large institutional investor in –  notifying Federal agencies about disputes relating to the rental of such properties, including disputes about potential violations of Federal law; sharing information about such disputes with other Federal agencies, including other Federal agencies that manage similar disputes; monitoring such disputes; and resolving such disputes, to the extent practicable.   Response to Outreach The HUD Secretary is required to establish reasonable procedures to promptly respond, in writing where appropriate, to a renter who provides information to the HUD Secretary about a dispute using the Renter Outreach Resource and document such responses.  Such responses are required to include, where appropriate, information about –  steps that have been taken by the HUD Secretary or another Federal agency in response to the information about the dispute provided by the renter, including determining the appropriate large institutional investor involved as described in the bullet below “Investigation of Potential Violations of Federal Law;” any responses received by the HUD Secretary or another Federal agency from the large institutional investor related to such dispute; and any outcome of the dispute, to the extent practicable.   Investigation of Potential Violations of Federal Law The HUD Secretary is required to promptly process and investigate any information relating to a dispute received through the Renter Outreach Resource about a potential violation of Federal law that is received from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, including –  requesting information from a large institutional investor; determining the appropriate large institutional investor involved in the dispute; and sharing information about such potential violation of Federal law with any relevant Federal agencies, as the HUD Secretary may determine appropriate.   Upon request for information made pursuant to the Renter Outreach Resource, the HUD Secretary is required to provide a large institutional investor the opportunity to respond, including regarding whether such large institutional investor currently owns the property described in such request for information.   Information for Appropriate State Authority When the HUD Secretary receives information about a potential violation of State law or about a dispute received through the Renter Outreach Resource, from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, the HUD Secretary is required, at a minimum, to provide the renter with contact information for the appropriate, State-specific, State authority authorized to process and investigate such information.   Notice About Renter Outreach Resource Each large institutional investor is required to –  provide to each renter of a residential property owned by such investor at the time such renter first occupies such home and annually thereafter –  written notice about the Renter Outreach Resource; and the name, phone number, and email address of the person or entity responsible for receiving and addressing renter disputes for the large institutional investor, and update the name, phone number, and email address within 30 days if such information changes prior to the subsequent time at which such notice is required to be provided; and   prominently feature information about the Renter Outreach Resource on a public website of such investor that is accessible by such renter.   Annual Notification Not later than 180 days after the date of enactment of the Housing Act, and not later than December 31st of each year thereafter, each person or entity that satisfies the definition of a large institutional investor is required to –  notify the HUD Secretary each year whether such owner is a large institutional investor; and in such notification, identify how many single-family homes such large institutional investor has direct or indirect investment control of as of the date of the submission of such notice, and the city and State where each such single-family home is located, unless such large institutional investor owns ten or fewer single-family homes in such city. Studies on Large Institutional Investors Not later than two years after the Effective Date, and again not later than ten years after the Effective Date, a GAO report and a HUD report are required to be submitted to the House Banking Committee and the Senate Committee on Financial Services. *     *     * Contacts Tax Cameron N. Cosby Carson Durdel Connie Lee Ameek Ashok Ponda Sarah D. Wellings Private Funds William C. Hanson Real Estate Karen J. Kepler Louis A. Monti John M. Steiner Appendix A Defined Terms in Section 1001 of the Housing Act Consumer Reporting Agency:  The term “consumer reporting agency” has the meaning given the term in section 603 of the Fair Credit Reporting Act (15 U.S.C. 1681a)). Excepted Purchase:  The term “excepted purchase” means any purchase of a single-family home that is –  Newly Constructed, For Sale Home Newly constructed, renovated, or a rental conversion for sale by a large institutional investor and not as a residence rented pending sale;   Build-to-Rent Program Pursuant to a build-to-rent program where the large institutional investor purchases newly constructed single-family homes to be managed as rental properties, whether as communities exclusively of renter-occupied single-family homes or as communities of single-family homes that are both owner- and renter-occupied;   Renovate-to-Rent Program Pursuant to a renovate-to-rent program that –  substantially rehabilitates single-family homes that do not meet structural or core system elements of local building codes; and makes improvements in an aggregate dollar amount of not less than 15% of the purchase price of the single-family home;   Homeownership Program Pursuant to a homeownership program that –  requires rental payments and any other fees that are not greater than those collected by the large institutional investor on other similarly situated single-family homes not covered by the eligible homeownership program; is subject to a contract between the large institutional investor and renter that shall be considered a consumer credit transaction secured by a dwelling or real property; provides for positive reporting of rental payments to consumer reporting agencies for any renter, who shall be informed of and opts into such reporting; and requires contribution of meaningful financial support from the large institutional investor, including price concessions, for the purchase of the single-family home by the renter;   Program to Boost Homeownership Pursuant to a program to boost homeownership that –  provides for positive reporting of rental payments to consumer reporting agencies for any renter who is informed of and opts into such reporting; provides for the right of first refusal and a 30-day ‘‘first look’’ period; and may entail the meaningful financial support from the large institutional investor, including price concessions, for the purchase of a single-family home by the renter (whether it is the home the renter occupies or another home);   Repossession In connection with the satisfaction of debts previously contracted in good faith and where the large institutional investor has the right to repossess the single-family home under such contract;   Foreclosure Undertaken by a mortgage servicer, lender, or other entity that has a legal right to a single-family home, for the purpose of loss mitigation or compliance with servicing or investor obligations, and not as a long-term investment strategy, and is solely as a result of –  a foreclosure; a deed-in-lieu of foreclosure; enforcement of a mortgage, deed of trust, or other security interest; or operation of law following borrower default;   Purchase from Another Large Institutional Investor Purchased from another large institutional investor that either owned the single-family home on the date of enactment of the Housing Act or purchased the single-family home in compliance with Section 1001;   Purchase from Investor Not a Large Institutional Investor Purchased from an investor not covered under Section 1001, so long as the purchase occurred not more than two years after the Effective Date;   Newly Constructed Single-Family Home in Senior Community Newly constructed, renovated, or a rental conversion that is intended and operated for occupancy as part of a community for households with one or more members aged 55 years or older, and satisfies visitability standards established by the HUD Secretary; or   Combination of Foregoing Purchases Purchased through a single purchase or combination or series of purchases described in the foregoing bullet points.   Large Institutional Investor:  The term “large institutional investor” means an investment fund, corporation, general or limited partnership, limited liability company, joint venture, association, or other for-profit entity that is a legal entity structured in a manner that is not aforementioned that –  is engaged, in whole or in part, in the business of investing in, owning, renting, managing, or holding single-family homes; and alone or in concert with one or more other entities, beginning after the date of enactment of the Housing Act, directly or indirectly has investment control of not less than 350 single-family homes in the aggregate, not including any single-family home purchased in an excepted purchase made after the date of enactment of the Housing Act.   A large institutional investor does not include any local, State, Tribal, or Federal government entity or instrumentality thereof. For purposes of the definition of “large institutional investor”, an entity has direct or indirect investment control over a single-family home if the entity –  owns, or has primary authority or fiduciary responsibility to make material investment or management decisions relating to, the single-family home; is, or directly or indirectly controls, the general partner or managing member of the entity that owns the single-family home; is or controls the investment manager, management company, or investment advisor of the entity that owns the single-family home; owns or controls more than 25% of any class of equity interests of the entity that owns the single-family home, unless such entity is a passive investor; or otherwise controls the entity that owns the single-family home.   Purchase:  The term “purchase” includes any purchase, transfer, or other acquisition of a single-family home, including through mergers, acquisitions, construction, foreclosures, or bulk purchases, whether or not for cash consideration.   Single-Family Home:  The term “single-family home” means a structure that contains two or fewer dwelling units that are each intended for residential occupancy by a single household.  The term “single-family home” does not include a manufactured home, as defined in section 603 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5402).
International M&A and Joint Ventures: Key U.S. Taxation Issues
Douglas Stransky, leader of the firm’s Tax practice group, authored “International M&A and Joint Ventures: Key U.S. Taxation Issues” published by LexisNexis in June 2026. The practice-oriented treatise focuses on the U.S. tax implications of cross-border mergers, acquisitions and joint ventures and incorporates recent legislative changes and international tax developments. It includes practice aids and aims to provide professionals strategies in navigating the complexities of cross-border transactions in an evolving tax landscape. LexisNexis® Legal & Professional is a leading global provider of AI-powered analytics and decision tools.
Douglas Stransky Publishes Treatise on Cross-Border Mergers, Acquisitions & Joint Ventures
Boston, MA – Sullivan & Worcester announces today that LexisNexis has published a treatise authored by Douglas S. Stransky, partner and leader of Sullivan’s Tax Practice Group. International M&A and Joint Ventures: Key U.S. Taxation Issues, is a comprehensive, practice-oriented treatise that examines the U.S. tax implications of cross-border mergers, acquisitions, and joint ventures. Written for practitioners, the treatise balances technical rigor with practical insight and provides guidance on complex tax considerations that arise in international transactions. Available in hard copy and e-book format, the work incorporates recent legislative changes and international tax developments, offering timely analysis for professionals operating in today’s rapidly evolving global tax environment. The only comprehensive, single-author treatise integrating cross-border M&A structuring, joint ventures, international tax regimes, transfer pricing, SALT, and compliance into one resource, eliminating the need to consult and synthesize multiple publications. “Cross-border transactions present increasingly complex tax issues that require both technical expertise and practical judgment,” Stransky said. “My goal is to provide a resource that not only explains the law, but helps practitioners apply it effectively in real-world situations.” Complete with practical tools and practice aids, the treatise equips tax advisors, attorneys, accountants, and corporate professionals with strategies to navigate the challenges of cross-border transactions and make informed decisions throughout the transaction lifecycle. More information is available at LexisNexis. About Sullivan Sullivan & Worcester (Sullivan) is a premier, AmLaw 200 international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Sullivan & Worcester Attorneys Named to the 2026 Lawdragon 500 Leading Global Tax Lawyers Guide
Boston, MA – Sullivan & Worcester announced that David Nagle, Ameek Ashok Ponda and Richard Jones were selected for inclusion in the 2026 Lawdragon 500 Leading Global Tax Lawyers guide. The guide recognizes attorneys for exceptional work in handling tax aspects of transactional matters, complex tax disputes and litigation, and advising private wealth clients and family offices.  Dave is managing partner of Sullivan. He represents companies in tax disputes before the Massachusetts Department of Revenue and the Internal Revenue Service. He also advises companies and individuals in tax audits, administrative appeals, and litigation and state tax issues related to transactions. His recent professional honors include Best Lawyers’ Boston Litigation and Controversy - Tax Law Lawyer of the Year, Boston Magazine Top Lawyers in Tax and International Tax Review’s World Tax Guide. Ameek advises clients on domestic and international taxation matters, with a focus on mergers and acquisitions and real estate investment trusts (REITs). He is nationally recognized for his work in REIT conversions and cross-border matters across a broad range of property sectors. He has received numerous industry honors, including Forbes America's Best-In-State Tax Lawyers, Boston Magazine Top Lawyers in Tax Law and was ranked by Chambers USA as a Recognized Practitioner in Tax (2006-2026) and REITs: Tax (2013-2026). Rich handles state and local tax litigation for companies in a wide range of industries and transactional planning related to corporate, personal income and sales tax matters. A skilled litigator, he has a successful track record of recent landmark victories in tax cases before the Massachusetts Supreme Judicial Court. He has received numerous professional awards, including Massachusetts Lawyers Weekly Go To Tax Lawyer in 2026 and Boston Magazine Top Lawyers in Tax Law, and was ranked by Chambers USA in Tax. About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.

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Horizon Beverage Group, Inc. Acquired by the World’s Preeminent Distributor of Beverage Alcohol

Sullivan represented Horizon Beverage Group Inc., one of New England’s premier alcohol distributors, in its sale to Southern Glazer’s Wine & Spirits, the world’s preeminent distributor of beverage alcohol. The acquisition marks an exciting expansion for Southern Glazer’s, adding Massachusetts and Rhode Island as the 46th and 47th markets in its U.S. footprint, alongside operations in Canada and the Caribbean.

“We are grateful to Horizon’s employees, customers, and partners for so many years of success, and this transition represents an even brighter future for all,” said Bob Epstein, CEO/President at Horizon. “We’re confident that Southern Glazer’s strength and scale will not only support a smooth integration, but also create new opportunities for growth and success.”

“We’re committed to maintaining the exceptional service that Horizon is known for while bringing the added benefits of being part of the Southern Glazer’s family,” added Jim Rubenstein, CEO/Treasurer at Horizon. “This partnership ensures stability and growth for all stakeholders and strengthens our ability to deliver value across the board.”

Lewis N. Segall, Charles E. Chambers Jr., Ida J. Vanto, Sharon G. Leifer, Steven M. Cunningham, Jr. and Christopher C. Curtis

Wonder Media Network (WMN) Acquired by the World's Largest Independent Podcast Company

Sullivan represented Wonder Media Network (WMN), a female-founded, audio-first creative studio based in New York City, in its sale to Acast, the world’s largest independent podcast company. "WMN’s mission is so tightly aligned with that of Acast - bringing important and changemaking stories to the world," said WMN CEO Jenny Kaplan. "Together, we will allow both creators and advertisers to reach new audiences, build successful businesses, and shape the future of audio."

Lewis N. Segall, Joel R. Carpenter, Amy E. Sheridan, Erika L. Todd, Johanna Colpritt and Nathan Kosik-Desmond

One of the Largest Global REITs and Its Subsidiary Form a New Joint Venture

Our marquee REIT and Tax teams advised American Tower Corporation (NYSE: AMT), one of the largest global REITs, and its subsidiary CoreSite in the formation of a new joint venture with Stonepeak, a leading alternative investment firm specializing in infrastructure and real property assets, to develop, build and operate an 18-megawatt data center in Denver, Colorado. CoreSite provides IT infrastructure that empowers enterprises and cloud, network and IT service providers to monetize and future-proof their digital businesses. The total estimated development costs for the 18-megawatt data center are expected to be more than $250 million.

Sullivan’s team was led by Ameek Ashok Ponda, director of the Tax Department, with Sullivan Tax partners Joel Carpenter and Sarah Wellings, and associate Connie Lee, contributing to the successful deal.

Ameek Ashok Ponda, Joel R. Carpenter, Sarah D. Wellings and Connie Lee

Nonprofit Network Drives Skills-First Movement for a More Equitable and Inclusive Future Workforce

Sullivan acts as outside general counsel for Skillsright, Inc., a nonprofit coalition of the country’s top employers and their CEOs with a mission of driving a skills-first movement to unlock career opportunities for talent without four-year degrees, for a more equitable and inclusive future workforce. Sullivan handles a wide range of matters including obtaining the organization’s nonprofit (Internal Revenue Code Section 501(c)(3)) status, advising on a variety of legal issues associated with the organization’s work, negotiating intellectual property rights, drafting employment offers and dealing with related employment and benefits issues, overseeing all contracting issues and advising on corporate governance.

Kimberly Herman, David A. Guadagnoli, Judith G.H. Edington, Erika L. Todd and Michael S. Palmisciano

Admiral Metals Acquired by Reliance Steel & Aluminum Co., Largest Metals Service Center Company in North America

Sullivan represented Admiral Metals who was acquired by Reliance Steel & Aluminium Co. (NYSE: RS). “Admiral Metals has built a strong reputation in the metals industry for providing specialty products, high levels of customer service and next-day delivery,” commented Jim Hoffman, Chief Executive Officer of Reliance. “We believe this acquisition will enable Admiral Metals to leverage Reliance’s scale in order to capitalize on further growth opportunities while maintaining its strong brand recognition. We are excited to welcome Admiral Metals to the Reliance Family of Companies, our 70th acquisition since our 1994 IPO.”

Lewis N. Segall, Victor N. Baltera and Sharon G. Leifer

Masy BioServices Acquired by a Leading Pharmaceutical and Biotech Contract Development and Manufacturing Organization

Sullivan represented Masy Systems Inc. ("Masy" or "Masy BioServices"), a preferred provider of cGMP Biostorage and pharma support services, in the sale of its Masy to Alcami Corporation, a leading pharmaceutical and biotech contract development and manufacturing organization (CDMO). 

Lewis N. Segall and Steven M. Cunningham, Jr.

Scientist holding DNA gel in front of samples for testing in laboratory

Sullivan Shares Cross-Border Deal of the Year Award With Two Clients at M&A Advisor Awards

In November 2021, Sullivan together with its clients Merger & Acquisition Services, Inc., and International Transportation Marine Office, LLC (ITMA) received the Cross-Border Deal of the Year ($50 to $100 million) Award, at the 20th Annual M&A Advisor Awards in New York City. The award was given for the sale of ITMA to MS Amlin Underwriting Limited, a UK company. Don Kaitz retained his role as chairman of Arizona-headquartered ITMA, and the business continued to be led by Eric Kaitz, Chief Executive Officer. Earlier in 2021, Douglas Stransky and Michael Student, along with Merger & Acquisition Services Inc., advised ITMA and the Kaitzes.

Partner and head of Sullivan's International Tax Group, Douglas Stransky, commented, "We are thrilled to receive this honor and be together in-person with our clients and friends, Merger & Acquisition Services, Inc. and Don and Eric Kaitz, and proud to have collaborated with them on this sale."

Douglas S. Stransky and Michael J. Student

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