ROBERT E. DALLMAN Taxation

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1 Taxation (414) / [email protected] EXPERIENCE PROFILE Robert Dallman is a shareholder in the Milwaukee office of Whyte Hirschboeck Dudek and chair of the Federal Taxation Team. Mr. Dallman's practice includes providing advice to clients in complex federal and state tax audits, administrative appeals and tax litigation; tax planning; and business planning. Formerly an IRS trial attorney in Washington, D.C. and Milwaukee, he has practiced either for or against the IRS and selected state taxing authorities for more than 20 years. Referred to by one client as the "dean of the Milwaukee Tax Bar" and another as the "dean of the Wisconsin Tax Bar," Mr. Dallman's clients describe him as a trusted advisor and advocate who is "very strategic," "dogged" and "goes for the jugular when needed." His experience as a former IRS attorney is especially valued by clients, one noting that Mr. Dallman "anticipates well given his prior IRS trial experience in Washington, D.C. and Milwaukee." Another tax executive describes Mr. Dallman as someone with the experience to know "when to step on the gas, back off, threaten and smile--all for my benefit." Another client concluded that he was the most creative federal tax controversy attorney in Wisconsin. Another client mentioned that "Mr. Dallman's reputation is well deserved." He has been rated as the top tax attorney in Wisconsin by one rating service. His experience includes the following technical tax areas: - Valuation - Apportionment - Intangibles - Residency - Ownership succession

2 - Contributions of easements - Executive compensation - Reasonable compensation - Mixing bowl transactions and other partnership issues - Charitable contributions - Transfer pricing - Payroll tax - Excise tax - Inventory - Purchase price allocations - REIT mirror transactions - UPREIT transactions - Estate and gift taxes - Tax accounting - Material distortion/clear reflection of income - Sham companies/sham transactions - Like-kind/Starker exchanges - Tax shelters (corporate and individual) - Preparer penalties - Tax shelter promoter penalties - Passive activity losses - Venture capital - LBOs - Debt-equity - Trust Preferred securities - Service corporations - Midco transactions - Selected insurance tax issues - Derivatives - Selected IRS attacks on offshore trusts - Indopco issues - International and domestic reorganizations and acquisitions - Selected other state and local tax His representative matters and experience include:

3 Tax audits and litigation, primarily complex domestic and international issues including representing clients before the U.S. Tax Court in numerous cities, the U.S. District Court in Michigan and Wisconsin, the U.S. Court of Federal Claims, the U.S. Court of Appeals for the Seventh Circuit, the Wisconsin Tax Appeals Commission, the Wisconsin Circuit Court and the Wisconsin Court of Appeals. One of the few practicing tax controversy attorneys in the United States (with former IRS trial experience and the only Wisconsin-based attorney) who is on the IRS "List of Neutrals," a list of individuals who could be chosen as a mediator or arbitrator of tax disputes between the IRS and taxpayers. Practiced against the IRS in Alabama, Arizona, California, Colorado, Florida, Georgia, Illinois, Indiana, Iowa, Maine, Maryland, Michigan, Minnesota, Missouri, New Jersey, New Mexico, New York, North Carolina, Pennsylvania, South Carolina, Texas, Virginia, Washington, D.C., West Virginia and Wisconsin. The only practicing tax attorney in Wisconsin to prevail in tax cases before the Wisconsin Tax Appeals Commission, the U.S. Tax Court, the Seventh Circuit Court of Appeals and the U.S. Court of Federal Claims. The only tax attorney in Wisconsin since at least 1999 to obtain reimbursement for a client from the IRS for the costs of litigation, an amount that was the then highest obtained by a taxpayer from the IRS in Wisconsin. Litigated significant cases in the areas of partnership taxation, valuation, gift tax, estate tax, the taxation of inventories, sham transactions and the income tax aspects of real estate transactions including like-kind/tax-deferred exchanges. Litigated landmark cases in the area of executive/reasonable compensation, Code Section 2703(b) and officer liability. Frequently speaks to professional organizations about: (1) practice and procedure before the IRS, U.S. Department of Justice and the Wisconsin Department of Revenue and (2) selected tax planning issues. Served as an adjunct faculty member in the University of Wisconsin-Milwaukee's graduate tax program, teaching a course on advanced corporate tax planning, another relating to the income tax aspects of real estate and another relating to tax shelters.

4 In excess of 30 trials in the federal tax courts and the Wisconsin tax commission. A listing of Mr. Dallman's cases (which have been resolved) is available here. A listing of Mr. Dallman's pending Federal tax issues is available here. PROFESSIONAL PROFILE Education Georgetown University, LL.M, Taxation The University of Kansas School of Law, J.D. Valparaiso University, B.A. Professional Associations IRS Liaison Committee in Wisconsin Milwaukee Tax Club (chair) Wisconsin State and Local Tax Club (founder) Milwaukee Bar Association (Tax section co-chair) State Bar of Wisconsin (Tax and Alternative Dispute Resolution sections) American Bar Association (Dispute Resolution Division and Tax Section) Awards & Distinctions The only Wisconsin tax attorney to be invited multiple times to the U.S. Judicial Tax Conference of the Tax Court Selected for inclusion in The Best Lawyers in America in Tax Law and Litigation & Controversy - Tax ( ) International Who's Who of Professionals Best in Class (U.S.A.) Attorneys Leading American Attorneys Marquis Who's Who in America Named to the Wisconsin Super Lawyers list ( ) Wisconsin Super Lawyers - Blue Ribbon panel Madison's Who's Who Who's Who in Executives and Professionals Cambridge Who's Who

5 Awards & Distinctions Continental Who's Who Rated AV Preeminent by Martindale-Hubbell American Registry's America's Most Honored Professionals Inaugural Selection Articles and Presentations Robert E. Dallman Profiled By In Business, IB Wisconsin's Professional of the Week (April 2012) Author and co-author, numerous other articles