Dan's practice focuses on representing taxpayers in federal and state tax litigation and controversies as well as transactional planning involving corporate, franchise, personal income and sales/use tax matters. Prior to his employment at Sullivan, Dan was an attorney at the Internal Revenue Service Office of Chief Counsel, where he represented the Internal Revenue Service in litigation before the United States Tax Court and served as a Special Assistant United States Attorney for the District of Massachusetts.
Dan is also one of the founders of the firm's Opportunity Zone practice group, and has assisted in the structuring of over $1 billion in Opportunity Zone projects throughout the country, including both real estate and operating business. Dan was named a Top 25 Tax Specialist by Opportunity Zone Magazine in 2022.
Representative Client Work
- 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 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
Bar & Court Admissions
- Massachusetts
- New York
- U.S. District Court, District of Massachusetts
- U.S. Tax Court
Education
- LL.M., Taxation, Boston University School of Law
- J.D., magna cum laude, Catholic University, Columbus School of Law
- B.A., Boston College
Community Engagement
- Boston Bar Association, Tax Section
- American Bar Association, Tax Section
Awards & Honors
- Top 25 Tax Specialist, Opportunity Zone Magazine (2022)
- The Legal 500 U.S. (2019, 2022)
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Sampan, QuotedJuly 13, 2022
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Boston Herald, QuotedJune 22, 2022
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Boston Business Journal, QuotedJune 22, 2022
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Press ReleaseJune 8, 2022
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The Boston Globe, QuotedMay 5, 2022
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Boston Herald, QuotedMay 3, 2022
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Law360, QuotedApril 27, 2022
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Press ReleaseApril 26, 2022
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Client AlertApril 13, 2022
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Law360 Tax Authority, QuotedFebruary 23, 2022
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Press ReleaseFebruary 17, 2022
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GlobeSt.com, QuotedDecember 17, 2021
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Press ReleaseJune 9, 2021
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Law360, QuotedMay 19, 2021
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Client AlertMay 17, 2021
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GlobeSt.com, QuotedApril 23, 2021
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Client AlertApril 22, 2021
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Sullivan PublicationApril 20, 2021
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The Real Deal, QuotedApril 15, 2021
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Bloomberg Tax, QuotedApril 13, 2021
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Law360, QuotedApril 12, 2021
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Internal Revenue Service Provides Additional COVID-19 Related Relief for Opportunity Zones InvestorsClient AlertJanuary 20, 2021
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Bloomberg Tax, QuotedSeptember 23, 2020
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Client AlertJune 25, 2020
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Client AlertJune 17, 2020
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Client AlertJune 9, 2020
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Client AlertJune 1, 2020
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Client AlertMay 14, 2020
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Client AlertMay 14, 2020
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Client AlertMay 7, 2020
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Client AlertApril 30, 2020
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Client AlertApril 20, 2020
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Client AlertFebruary 11, 2020
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Sullivan Press ReleaseMay 30, 2019
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Opportunity Zones Client AlertApril 19, 2019
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Commercial Property Executive, QuotedJanuary 15, 2019
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Affordable Housing FinanceJanuary 11, 2019
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Real Estate Finance & Investment, QuotedJanuary 9, 2019
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Opportunity Zones AlertNovember 9, 2018
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Opportunity Zones AlertOctober 22, 2018
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Client AlertJune 13, 2018
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Client AdvisoryApril 18, 2018
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Law360April 13, 2018
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Client AdvisoryMarch 26, 2018
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Massachusetts Taxation and DOR PracticeJanuary 30, 2018
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Press ReleaseJanuary 8, 2018
Seminars & Presentations
- QOF Talk: Structuring and Operating Strategies
Novogradac's 2021 Fall Conference, Cleveland, OH (October 21, 2021) - 2021 Opportunity Zone Expo
Denver, Colorado (July 15, 2021) - The OZ Act After COVID-19: Where We Go From Here
Virtual Program (May 19, 2020) - Opportunity Zone Updates
Massachusetts Society of CPAs (MSCPA) (July 16, 2019) - Opportunity Zones
Massachusetts Society of CPAs (MSCPA) (June 20, 2019) - New Orleans Investment Summit
New Orleans Business Alliance (June 13, 2019) - North Atlantic Regional State Tax Seminar
Council on State Taxation (May 9, 2019) - QOZs: The changing landscape for deal-makers
RSM (March 28, 2019) - Opportunity Zones: Where Are We After A Year?
Boston Bar Association (January 22, 2019) - Worcester's Opportunity Zones
Worcester Regional Chamber of Commerce (January 9, 2019) - Opportunity Zones: An Overview of the Latest Tax Incentive for Investors
Sullivan & Worcester and Pickwick Capital Partners (January 7, 2019) - Webinar Replay: Qualified Opportunity Funds
Gemini (December 5, 2018) - Securing Massachusetts and Local Tax Incentives to Maximize Opportunity Zone Benefits for Developers and Investors
Sullivan & Worcester Conference Center, Boston, MA (November 29, 2018) - The Land of OZ Explained – Understanding the New Opportunity Zone Proposed Regulations
Sullivan & Worcester Conference Center (November 8, 2018) - Opportunity Zones Presentation to MSCPA Tax Committee
Massachusetts Society of CPAs (June 19, 2018) - State Tax Appeal Protests and Procedures — The Dos and Don'ts
North Atlantic Regional State Tax Seminar (May 16, 2018) - The 11th Annual Worldwide Tax Update
Sullivan & Worcester Conference Center (May 15, 2018) - Representing Taxpayers Before the IRS and DOR
Sullivan & Worcester, One Post Office Square, 21st floor, Boston, MA (May 24, 2017) - Domicile and Residency Issues for Individuals and Estates - Planning, Audits and Appeals
Sheraton, Framingham, MA (January 17, 2017)