Representative examples of legal services include:

• Representing clients in a district court litigation relating to FBAR penalties;
• Advising U.S. citizens living or working abroad, foreign nationals residing and working in the U.S., and foreign entities doing business in the U.S. about coming into tax compliance concerning their foreign assets and business interests;
• Representing clients in sensitive civil tax examinations by the IRS where fraud, substantial penalty issues, and/or criminal referral may arise;
• Counseling advisors and other professionals on tax matters arising from investigations with U.S. regulators;
• Defending clients in U.S. and state residency audits;
• Advising clients throughout various stages of tax disputes with the IRS resulting from their domestic and offshore holdings;
• Guiding clients through the IRS or state voluntary disclosure processes;
• Representing clients in civil and criminal tax disputes with New York and New Jersey in connection with employment tax and sales tax issues; and
• Defending clients in criminal investigations and civil examinations in connection with underpayments and/or underreporting of employment tax.

• New York University School of Law, New York, NY
  • LL.M. in Taxation
• New York Law School, New York, NY
  • Juris Doctor
  • Honors: magna cum laude
• New York University, New York, NY
  • Bachelor of Fine Arts

States/Jurisdictions: 

• New York
• New Jersey
• District of Columbia

Courts: 

• U.S. Supreme Court
• U.S. Court of Appeals for the Second Circuit
• U.S. Tax Court
• U.S. Court of Federal Claims
• U.S. District Court, Southern District of New York
• U.S. District Court, Eastern District of New York
• U.S. District Court, Western District of New York
• U.S. District Court, District of New Jersey

• Co-author, New Edition of Bloomberg BNA Tax Management Portfolio, “Report of Foreign Bank and Financial Accounts,” 2025 Publication (expected)
• Co-author, Center for Taxpayer Rights’ amicus curiae brief in the Supreme Court of the United States case Bittner v. United States, quoted in the Court’s opinion.  
• Co-Author, American Bar Association Section of Taxation comments on proposed amendments to the Tax Court rules of practice and procedure, May 25, 2022.  LINK
• Co-Author, “Decrypting The New IRS Cryptocurrency Compliance Letters”, Law360 Tax Authority, August 7, 2019
• Co-Author, “Deal or No Deal: The Unknown Cost of the IRS’s New Voluntary Disclosure Practice”, White Collar Crime Committee Newsletter, February 28, 2019
• Co-Author, “INSIGHT: Last call for OVDP: Use It or Lose It”, Bloomberg Tax: Daily Tax Report, April 20, 2018
• Author, “IRS Launches Issue Based Corporate Compliance Campaigns”, Global Tax Weekly, February 16, 2017
• Co-Author, Report of Foreign Bank and Financial Accounts (FBAR), (Book), Bloomberg BNA’s Tax Management Portfolio, June 29, 2016,
• Author, “U.S. Offshore Account Enforcement Issues,” CCH’s Journal of Tax Practice & Procedure, September 30, 2014
• Author, “The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court,” The Practical Tax Lawyer, December 1, 2012
• Comments to the Proposed Amendments to the Rules of the United States Tax Court, American Bar Association, March 7, 2011
• Comments to the Proposed Amendments to the Rules of the United States Tax Court, American Bar Association, May 27, 2009
• Selected Recent Developments in Administrative Practice, American Bar Association (May Meeting, Administrative Practice Committee), May 8, 2009

• Fellow, American College of Tax Counsel
• Member, American Bar Association, Section of Taxation
  • Current Chair, Court Practice and Procedure Committee
  • Former Vice-Chair, Court Practice and Procedure Committee
  • Former Co-Chair, Subcommittee on Offshore Enforcement for Civil and Criminal Tax Penalties Committee
• Member, New York State Bar Association
• Member, Federal Bar Association

• “Leading Lawyer” in US Taxes: Contentious, USA, 2024 by Legal 500
• “Lawyer of the Year” in Litigation and Controversy-Tax, New York, 2023 by Best Lawyers
• “The Best Lawyers in America in Tax Law,” 2025
• “The Best Lawyers in America in Litigation and Controversy Tax,” 2021-2025
• “ Chambers High Net Worth, USA, Tax: Private Client,” 2022-2024
• “The Legal 500, Next Generation Lawyers,” 2018-Present; Recommended, 2017 – Present
• “Super Lawyers in Tax (New York Metro List),” 2023-2024
• “Super Lawyers New York Rising Star,” 2013 – 2017
• “The American Lawyer’s Global Legal Award, Global Dispute of the Year: Investigations,” Swiss Tax Settlements, 2015
• “Nolan Fellowship, American Bar Association, Section of Taxation”, 2013

2025

• Chair, Court Practice and Procedure committee meeting at the American Bar Association Section of Taxation 2025 May Meeting.
• Presenter, “Keeping It Civil: How to Prevent a Civil Matter from Turning Criminal,” the American Bar Association, Section of Taxation, 2025 Midyear Meeting

2024

• Presenter, “Voluntary Disclosure: Where Are We Now?” panel at the 2024 ABA 41st Annual National Institute on Criminal Tax Fraud in Las Vegas, NV on December 13, 2024
• Presenter, “I Always Think That Everything Could Be A Trap: Ethical Dilemmas in Tax Controversy,” the American Bar Association Webinar, August 13, 2024 
• Presenter, “Challenging Civil Penalties – Recent Developments,” NYU Tax Controversy Forum, New York, NY, June 27, 2024
• Panelist, at the 21st Annual Tax Lawyering Workshop, New York Law School on Avoiding the Ethical Quagmire in Tax Controversy, 21st Annual Tax Lawyering, NYU Law School Workshop, New York, May 17, 2024

2023

• Presenter, “When You Should Know Something That the Government Does Not: Ethical Considerations in Keeping Your Civil Case from Going Criminal” panel at the 2023 ABA 40th Annual National Institute on Criminal Tax Fraud in Las Vegas, NV on December 8, 2023
• Speaker, “FBAR penalties that the IRS issues and the impact of the Supreme Court’s decision in Bittner v. U.S.,” NYU Tax Controversy Forum, New York, June 10, 2023
• Speaker, “Current Developments in Case Law,” 8th International Conference on Taxpayer Rights, Santiago, Chile, May 25, 2023
• Presenter, “IRS International Penalties after Farhey,” Beverly Hills Bar Association, Webinar, May 18, 2023
• Presenter, “Cryptocurrencies,” Federal Bar Association Tax Law Conference, Washington, DC, March 6, 2023

2022

• Presenter, “Ethics Issues Presented by Conflicts of Interest in Tax Cases—Caution is the Watchword,” 2022 American Bar Association 39th National Institute on Criminal Tax Fraud and 12th Annual National Institute on Tax Controversy, Las Vegas, December 11 -13, 2022
• Presenter, “Estate & Gift Update Part 2: Pitfalls When Handling the Estate and Why the Tax Returns Matter!” and “Gotcha: Challenging Tax Penalties on International Forms,” 2022 New England IRS Representation Conference in New Haven, CT, November 18, 2022
• Presenter, “Litigation Update: The Latest on FBAR and Other International Information Return Penalties,” DC Bar Association, Virtual, June 30, 2022
• Presenter, “Cryptocurrency Update” and “Cleaning Up the Client’s Mess-Voluntary Disclosure,” Criminal Tax Day 2022, Live in-person and Webcast Event, Quinnipiac University School of Law, New Haven, CT, June 10, 2022
• Co-Presenter, “Foreign Financial Asset Reporting-Learn From Tax Attorneys,” CDH CPA, Webinar, May 19, 2022
• Panelist, “Structuring a Tax Representation: Privilege, Fees and Other Considerations” 19th Annual Tax Lawyering Workshop: Tax Practice in a Changing World, New York University Law School, April 29, 2022
• Panelist, “Foreign Trusts” and “Trust like Structures,” 2022 Tax Institute (Virtual Event), USC Gould School of Law, January 26, 2022

2021

• Panelist, “The Attorney-Client Privilege and Work Product Protection in Tax Court – Developments and Best Practices (Ethics),” 2021 American Bar Association 38th National Institute on Criminal Tax Fraud and 11th Annual National Institute on Tax Controversy, Las Vegas, December 11-13, 2021
• Panelist, “The IRS’s Use of Data & AI in Enforcement,” 2021 IRS Representation Conference, Virtual, November 19, 2021
• Panelist, “Tax Controversies,” NYU’s 80th Institute on Federal Taxation, Virtual, November 15, 2021
• Panelist, “FBAR Litigation Developments,” STEP USA, Webinar, October 21, 2021
• Panelist, “The Cost of Cheating: U.S. and U.K. Enforcement to Deter Non-Compliance,” Thirty-Eighth Cambridge International Symposium on Economic Crime, Cambridge UK, September 7, 2021.   
• Speaker, “Paycheck Protection Program Loan Fraud,” 4th Annual Criminal Tax Day, New England, May 28, 2021

2020

• Speaker, “Section on Taxation: Developments in FBAR Litigation and Enforcement,” Federal Bar Association, December 17, 2020
• Panelist, “FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, FBAR Defense Strategies, Recent Cases, Penalties,” Strafford Publications, Virtual, September 24, 2020
• Panelist, “New IRS Cryptocurrency Guidance on Hard Forks and Airdrops: Rev. Rul. 2019-24, Audit Risks for U.S. Taxpayers,” Strafford Publications, Webinar, February 27, 2020
• Panelist, “Preparing For and Managing an IRS Examination with Virtual Currency Issues,” ABA Section of Taxation 2020 ABA Midyear Meeting, Virtual, January 31, 2020
• Panelist, “Collections of Foreign Tax Judgments: When Your Other Problems Come Home,” ABA Section of Taxation, 2020 ABA Midyear Meeting, Virtual, January 31, 2020

2019

• Panelist, “Track B: Summons & Summons Enforcement, 2019 IRS Representation Conference,” EVENT NAME, LOCATION, November 22, 2019
• Panelist, “Ethical Obligations to Report Misconduct on by Other Practitioners and Taxpayers,” 2019 IRS Representation Conference, LOCATION, November 22, 2019
• Panelist, “Current Developments in FBAR Civil Penalty Litigation, Master Class,” The Graduate Tax Program, New York University Law School, November 20, 2019
• Panelist, “The Benefits and Limitations of Privileges: Attorney-Client (Kovel), Spousal, Accountant and Work Product, Shopping the Preparer: IRS Criminal Investigations of Tax Preparers,” 3rd Annual Criminal Tax Day, New England, May 2019
• Panelist, “Important Developments in Civil and Criminal Tax Penalties: Offshore Compliance and Enforcement,” 2019 ABA Section of Taxation, LOCATION, May 11, 2019
• Panelist, “Important Developments in Civil and Criminal Tax Penalties: Offshore Compliance and Enforcement,” ABA Section of Taxation 2019 ABA Midyear Meeting, LOCATION, January 19, 2019

2018

• Panelist, “Litigating Foreign-Related Penalties,” American Bar Association 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, LOCATION, December 14, 2018
• Panelist, “Litigating Title 31 FBAR Penalties: The Fundamentals,” 2018 Annual Meeting of the California Tax Bar and California Tax Policy Conference, LOCATION, November 8, 2018
• Panelist, “Civil and Criminal Tax Penalties – Reports of Subcommittees on Important Developments,” American Bar Association 2018 Fall Meeting, LOCATION, October 6, 2018
• Panelist, “Post-Mayo Jurisprudence: Challenging Regulations,” American Bar Association 2018 Fall Meeting, LOCATION, October 5, 2018
• Panelist, “Current Event in International Civil and Criminal Tax Enforcement,” The International Tax Enforcement Update, LOCATION, June 14, 2018
• Panelist, “Bringing Your Client in from the Cold, The Criminal Tax Case: When Criminal Investigators Come Knocking,” 2nd Annual Criminal Tax Day, New England, May 17, 2018
• Panelist, “Dealing with the Undocumented Worker, The Criminal Tax Case: When Criminal Investigators Come Knocking,” 2nd Annual Criminal Tax Day, New England, May 17, 2018
• Panelist, “Civil and Criminal Tax Penalties – Reports of Subcommittees on Important Developments,” 2018 ABA Section of Taxation May Meeting, LOCATION, May 12, 2018
• Panelist, “Ethics Issues in Criminal Representations,” 2018 ABA Section of Taxation May Meeting, LOCATION, May 11, 2018
• Panelist, “Taking Positions Contrary to Regulations: Update on Deference and Disclosure,” NYLS 15th Annual Tax Lawyering Workshop, LOCATION, May 3, 2018
• Panelist, “Tax Planning for the High Net Worth Individuals,” 2018 Annual Tax Planning Strategies, U.S. and Europe, Wealth Management Program, Amsterdam, Netherlands, April 11, 2018 
• Panelist, “Civil and Criminal Tax Penalties: Reports of Subcommittees on Important Developments – Offshore Compliance and Enforcement,” American Bar Association Section of Taxation 2018 Midyear Meeting, LOCATION, February 10, 2018
• Panelist, “Tax Collection, Bankruptcy and Workouts: Recent Developments,” American Bar Association Section of Taxation 2018 Midyear Meeting, LOCATION, February 9, 2018

2017

• Panelist, “Waking Up the Dead: Reopening Those Tax Assessments You Thought Were Final,” IRS Representation Conference, New England, November 17, 2017
• Speaker, “Important Developments in Civil and Criminal Tax Penalties,” ABA Section of Taxation, 2017 Joint Fall CLE Meeting, LOCATION, September 16, 2017
• Speaker, “Developments in FBAR Litigation,” ABA Section of Taxation, Administrative Practice Committee Monthly Call, Virtual, July 19, 2017
• Presenter, “International Tax Enforcement Update,” Agostino & Associates’ Civil and Criminal International Tax Enforcement Update, LOCATION, June 14, 2017
• Panelist, “International Information Reporting,” 2017 ABA Section of Taxation May Meeting, LOCATION, May 13, 2017
• Presenter, “Offshore Enforcement Update,” 2017 ABA Section of Taxation May Meeting, LOCATION, May 13, 2017
• Panelist, “How to Affirmatively Defend An FBAR Case,” American Bar Association 2017 Midyear Meeting, LOCATION, January 20, 2017

2016

• Moderator, “It’s a Small World After All: Evidence in Offshore Non-Compliance Cases (Part I),” American Bar Association 2016 Joint Fall Meeting, LOCATION, October 1, 2016
• Moderator, It’s a Small World After All: Evidence in Offshore Non-Compliance Cases (Part II), American Bar Association 2016 Joint Fall Meeting, LOCATION, September 30, 2016
• Speaker, “One Taxpayer’s Underpayment is Another’s Treasure: Whistleblower Awards Under Section 7623,” American Academy of Attorney-CPAs, LOCATION, June 24, 2016
• Speaker, “The International Enforcement Arena,” American Academy of Attorney-CPAs, LOCATION, June 24, 2016
• Speaker, “Nuts & Bolts of Tax Court Litigation: Pre-Trial,” ABA Tax Section, LOCATION, January 30, 2016
• Speaker, “The Other Shoe is Dropping – Criminal Enforcement and Civil Assessment and Collection of FBAR and International Information Return Penalties,” ABA Tax Section, LOCATION, January 29, 2016

2010-2015

• Panelist, “Offshore Account Disclosure Case Update,” ABA Section of Taxation January Meeting Court Procedure and Practice, Houston, Texas, January 30, 2015
• Panelist, “2014 OVDP and Streamlined Procedures – An Update,” ABA Section of Taxation Fall Meeting Civil and Criminal Tax Penalties Committee, Denver, Colorado, September 20, 2014
• Panelist, “’New and Improved’ June 2014 IRS Offshore Voluntary Disclosure Program—Version 3.0: Including ‘Streamlined’ Rules That Are Game Changer,” The State Bar of California Taxation Section, Webinar, July 17, 2014
• Panelist, “Court Procedure and Practice,” Tax Bridge to Practice ABA Section of Taxation May Meeting, Washington, D.C., May 9, 2013
• Moderator, “Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties,” ABA Section of Taxation Court Procedure and Practice Committee, Webinar, April 10, 2013
• Moderator, “Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties,” ABA Section of Taxation January Meeting Court Procedure and Practice Committee, Orlando, Florida, January 16, 2013
• Moderator, “Through the Looking Glass (Part I and II): Opting out of the OVDI Penalty Structure and Litigating FBAR Penalties,” ABA Section of Taxation Court Procedure and Practice Committee, Webinar, January 16, 2013
• Moderator, “Through the Looking Glass (Part II): Litigating FBAR Penalties,” ABA Section of Taxation Fall Meeting Court Procedure and Practice Committee, Boston, Massachusetts, September 2012
• Moderator, “Nuts & Bolts of Deficiency Cases: From Examination to the Tax Court,” ABA Section of Taxation 2012 May Meeting Court Procedure and Practice Committee, Washington, D.C., May 2012
• Moderator, “Court Procedure Issues in CDP Judicial Review,” ABA Section of Taxation February Meeting Court Procedure and Practice Committee, San Diego, California, February 2012
• Speaker and Author, “Current Developments,” ABA Section of Taxation Fall Meeting Court Procedure and Practice Committee, Denver, Colorado, October 2011
• Speaker and Author, “Current Developments,” ABA Section of Taxation January Meeting Court Procedure and Practice Committee, Boca Raton, Florida, January 2011

Speaker, “Judicial Deference Mock Argument: Application of Temp. Treas. Reg. § 301.6501(e)-1T(a)(1)(iii) in Smith v. Commissioner,” ABA Section of Taxation January Meeting Court Procedure and Practice Committee, San Antonio, Texas, January 2010