Jeff regularly advises clients during IRS examinations and proceedings before the IRS Independent Office of Appeals, helping navigate high-stakes disputes and achieve efficient resolutions. His practice spans a broad range of tax controversy matters, including complex partnership issues, accounting method changes, foreign tax credits, research and domestic production deductions, and compensation-related issues. He also represents clients in areas of heightened IRS scrutiny, including syndicated conservation easement transactions and micro-captive insurance arrangements. His clients include Fortune-listed companies, private equity firms, professional sports franchises, closely held businesses, and high-net-worth individuals.

Jeff has significant experience at the intersection of tax law and administrative law, including successfully arguing that the Tax Court should reverse prior precedent and hold a Treasury regulation procedurally invalid under the Administrative Procedure Act. His ability to combine technical tax knowledge with strategic litigation insight allows him to effectively defend clients’ positions in complex and evolving regulatory environments.

Previously, Jeff led the regional tax controversy practice for a Big Four accounting firm, where he assisted clients in resolving disputes administratively within the IRS, either while still in examination or in appeals. Jeff began his career with the IRS Office of Chief Counsel as a litigator and was eventually appointed as a Special Trial Attorney in the Large Business and International Division, where he was responsible for advancing some of the most important, sensitive, and complex cases before the Tax Court.