Caroline D. Ciraolo, Partner

Transcription

1 Caroline D. Ciraolo, Partner (410) Practice Group: Tax Controversy About Caroline Caroline D. Ciraolo defends individuals and businesses in federal and state civil tax controversies, civil tax litigation, and criminal tax investigations and prosecutions. She is a Fellow and Regent of the American College of Tax Counsel, a vice-chair of the ABA Section of Taxation s Civil and Criminal Tax Penalties Committee ( CCTP ), and former chair of the Maryland State Bar Association Taxation Section ( ). She has been recognized by Chamber USA (Nationwide: Tax Fraud), Benchmark: American s Leading Litigation Firms and Attorneys; Best Lawyers in America (Lawyer of the Year (2012), Litigation and Controversy Tax (Baltimore)), and Maryland SuperLawyers (Top 10 Attorneys, Top 50 Women Attorneys). Caroline regularly appears on behalf of her clients before the Internal Revenue Service, the Comptroller of Maryland, and the D.C. Office of Tax and Revenue. She litigates cases before the Maryland Tax Court, U.S. Tax Court, and the U.S. District Court, and handles appeals before the Maryland appellate courts and the U.S. Court of Appeals for the Fourth Circuit. Education University of Baltimore School of Law, LL.M. in Taxation (1994) University of Maryland, School of Law, J.D. (Honors) (1993) The College of New Jersey, B.S. in Finance (Honors) (cum laude) (1990) Bar Admissions Maryland Pennsylvania New Jersey District of Columbia US Tax Court US District Court, District of Maryland US Court of Federal Claims US Court of Appeals, Fourth Circuit US Supreme Court

2 P a g e 2 Memberships & Affiliations Fellow and Regent, American College of Tax Counsel Fellow, Litigation Counsel of America Fellow, Maryland Bar Foundation Trustee, Baltimore Bar Foundation MD State Bar Association: Taxation Section - Council ( ); Chair ( ); Chair-Elect ( ); Secretary/ Treasurer ( ); Tax Controversy Group, Founder, Chair ( ), and Advisor ( present) American Bar Association, Section of Taxation - Civil and Criminal Tax Penalties Committee [Vice-Chair ( present); Sub-Committee Chair - Important Criminal Developments ( )]; Nominating Committee ( ); Public Fellowship Committee ( ); Pro Bono Award Committee ( ) Member, Serjeant s Inn Member, Rule Day Club Member, Barrister s Club Panel Attorney, Criminal Justice Act, U.S. Court of Appeals for the Fourth Circuit Member, Network 2000 o Co-chair, Women of Excellence Luncheon (2013 present) o Member, Board of Directors (2014) Member, Board of Directors, Maryland Volunteer Lawyer Service ( present) o Chair, Annual Benefit ( present) Member, Board of Directors, Federal Bar Association (Maryland Chapter) (2014) Member, Day 4 Committee (State and Local Tax), Advanced Tax Institute, Maryland State Bar Association and Maryland Association of CPAs (2006-present) Member, Advisory Board, Thomson West Tax (2007 present) Member, Tax Advisory Board, Wolters Kluwer (2013 present) Member, Advisory Board, CCH Journal of Tax Practice & Procedure (2011 present) Instructor, Military Volunteer Income Tax Assistance (VITA) Program, Fort George G. Meade, Fort Meade, Maryland (2012 present) Member, Advisory Board, Choice Jobs Program ( present) Member, Advisory Board, Fannie Angelos Program for Academic Excellence (2014) Sponsor, U.S. Naval Academy Sponsor Program ( present) Awards & Honors Chambers USA, Nationwide: Tax Fraud ( ) Best Lawyers in America - Litigation & Controversy Tax ( ); Lawyer of the Year, Litigation & Controversy - Tax (2012) (Baltimore) Nominee (shortlist), Euromoney Legal Media Group s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014) Maryland Super Lawyers (Tax) ( ); Top 10 Attorneys in Maryland ( ); Top 25 Women Attorneys in Maryland ( ); Top 50 Women Attorneys in Maryland ( ); Top 100 Attorneys in Maryland ( )

3 P a g e 3 Featured in CNN Money Magazine Money Hero (April 2013) Featured on the cover of Maryland Super Lawyers Magazine (2013) Benchmark: America's Leading Litigation Firms and Attorneys ( ) Baltimore SmartCEO Magazine's Legal Elite (2009, 2010) Martindale-Hubbell Bar Register of Preeminent Women Lawyers Janet R. Spragens Pro Bono Award, ABA Section of Taxation (2010) The Daily Record's Top 100 Women in Maryland (2010, 2012, 2014) The Daily Record s Circle of Excellence (Women in Maryland) (2014) Maryland Volunteer Lawyers Service Educator Award (2008) U.S. Tax Court Pro Bono Program, Maryland State Bar Association Founder (2008/2009), Coordinator ( ), Volunteer (2008-present) o U.S. Tax Clinic Pro Bono Clinic Co-Founder (2013), Volunteer (2013-present) Judge, Public Service Fellowship, ABA Section of Taxation ( ) Judge, Law Student Tax Challenge, ABA Section of Taxation ( present) Judge, Janet R. Spragens Pro Bono Award, ABA Section of Taxation ( present) Publications Circular 230 Final Regulations and a New Principles-Based Approach, CCH's Journal of Tax Practice & Procedure (JTP&P) (August-September, 2014) The Ins and Outs of Federal Criminal Tax Cases, Maryland Bar Bulletin (April, 2014) The Tax Man is Coming Bank: A Word of Warning to Liquor Retailers, The Barrister (December 2013/January 2014) The United States Strikes Again The New Swiss Bank Program, Financier Worldwide (October, 2013) The Reasonable Cause Defense to Penalties and Some Good News for Taxpayers, CCH's Journal of Tax Practice & Procedure (JTP&P) (August-September, 2013) The FBAR Penalty: What Constitutes Willfulness?, Maryland Bar Journal (Taxation Issue, May-June, 2013) The Eggshell Audit Part II: Indicators of Fraud and IRS Fraud Development Procedures, with Larry Campagna and Eric Green, JTP&P (February-March, 2013) But I Relied on My Accountant! The Scope of the Reasonable Cause Defense to Penalties, co-authored with Larry Campagna and Ellis Reemer, JTP&P (August-September, 2012) The Eggshell Audit Part I: A Primer, with Larry Campagna and Eric Green, JTP&P (June-July, 2012) Criminal Tax Cases: A Primer, a chapter in Inside the Minds: Strategies for Criminal Tax Cases, Aspatore (2011) Last Known Address, a chapter in the recently published, Effectively Representing your Client before the Internal Revenue Service, 5th Edition (ABA Section of Taxation (2011)) Frequently Charged Tax Crimes, Federal Public Defender National Conference, June, 2011 Refund Claims and Claims for Contribution, ABA Section of Taxation (May, 2011) Editor, A Practitioner's Guide to Innocent Spouse Relief: Proven Strategies for Winning Section 6015 Tax Cases, by Robert B. Nadler (ABA Section of Taxation (2011)) FinCEN Issues Final FBAR Regulations, CCH JTP&P (April-May, 2011) The Morning After What You Need to Know FBAR and International Information Returns Including Defending Against and Litigating the Penalties, JTP&P (October-November, 2009)

4 P a g e 4 Attaching Property Held as Tenancy by the Entirety: The Response to Craft, JTP&P (January 1, 2004) Ask the Professionals (Various Tax-Related Topics), Baltimore Business Journal (2010 present) Speaking Engagements Institute Co-Chair, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, Las Vegas, NV (December 10-12, 2014) Panelist, Comprehensive Tax Enforcement, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, Las Vegas, NV (December 11, 2014) Moderator, Criminal Tax Workshop, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, Las Vegas, NV (December 10, 2014) Panelist, Criminal Tax Investigations: What To Do When Either You or Your Client is Contacted by an IRS Special Agent, New England IRS Representation Conference, Ledyard, CT (November 21, 2014) Panelist, Eggshell Audits: Handling Civil Exams When There are Indications of Fraud, New England IRS Representation Conference, Ledyard, CT (November 21, 2014) Panelist, Circular 230 & Reverse Circular 230: Ethical Issues for Practitioners Dealing with the IRS, and Ethical Issues for IRS Personnel When Dealing with Taxpayers and Practitioners, New England IRS Representation Conference, Ledyard, CT (November 21, 2014) Panelist, Hot Topics in Tax Enforcement, 25 th Annual Philadelphia Tax Conference, Philadelphia, PA (November 6, 2014) Panelist, Litigation Forums and Key Procedures, Bloomberg BNA, Resolving IRS Tax Controversies, New York, New York (October 28, 2014) Panelist, Eggshell Audits: Handling Federal Tax Audits when there are Potential Badges of Fraud, Bloomberg BNA, Resolving IRS Tax Controversies, New York, New York (October 27, 2014) Conference Co-Chair, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 16-17, 2014) Panelist, Ethics, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2014) Panelist, Relief from Joint and Several Liability, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 16, 2014) Panelist, Tax Controversy Clinic, Maryland Volunteer Lawyers Service, Baltimore, MD (October 2, 2014) Moderator, Statutes of Limitations in International Civil and Criminal Tax Matters The Rules and the Many Exceptions, Fall Meeting, ABA Section of Taxation, Denver, CO (September 20, 2014) Panelist, ABCs of FBARs, Western Union, Webinar (July 28, 2014) Speaker, Immigration and Taxation, IRS Nationwide Tax Forum, New Orleans, LA (July 24, 2014) Panelist, Global Tax Enforcement Conference, Villa Marina, Douglas, Isle of Man (July 3, 2014) Panelist, International Tax Enforcement Update, Teaneck, NJ (June 27, 2014) Moderator, Good Practitioner/Bad Practitioner Ethical Standards and Issues in Federal Tax Practice, NYU 6th Annual Tax Controversy Forum, New York, NY (June 20, 2014) Speaker, Foreign Tax Issues, Maryland Society of Accounting & Tax Professionals, Gaithersburg, MD (June 12, 2014) Panelist, Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There are Criminal Tax Issues, May Meeting, ABA Section of Taxation, Washington, DC (May 9, 2014) Panelist, The Top 10 Tax Issues for 2014, May Meeting, ABA Section of Taxation, Washington, DC (May 8, 2014)

5 P a g e 5 Panelist, Criminal Tax Update, Association of Federal Defense Attorneys (AFDA), Webinar (April 25, 2014) Panelist, Symposium: U.S. Taxpayers Foreign Accounts: FATCA, Voluntary Disclosure & Summonses Documents, Graduate Tax Program, University of Baltimore School of Law and Taxation Section, Maryland State Bar Association (March 24, 2014) Moderator, Coming into Compliance, 2d Annual International Tax Enforcement Conference, ABA Section of Taxation and Tax Executives Institute, Washington, D.C. (March 18, 2014) Panelist, Ethical Issues Arising from Conflicts of Interest in Litigation, Midyear Meeting, ABA Section of Taxation, Phoenix, AZ (January 24, 2014) Panelist, Business Development for Young Lawyers, Midyear Meeting, ABA Section of Taxation, Phoenix, AZ (January 24, 2014) Conference Co-Chair, ALI CLE - Hot Topics for Accountants & Tax Lawyers: Tax Returns, Advice, & Examination, Philadelphia, PA (December 16, 2013) Institute Co-Chair, 30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV (December 11-13, 2013) Moderator, Criminal Tax Workshop: The Basics, 30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV (December 11, 2013) Panelist, Commonly Charged Tax Crimes and Emerging Trends, University of Texas School of Law 61 st Annual Taxation Conference, Austin, TX (December 5, 2013) Panelist, Money & Time: Sentencing Trends in Criminal Tax Cases, 2013 White Collar Practice Seminar, Pennsylvania Association of Criminal Defense Lawyers, Philadelphia, PA (November 14, 2013) Panelist, Penalty Relief - Defensive Strategies and Practical Considerations, American Institute of Certified Public Accountants (AICPA), 2013 Tax Controversy Workshop, Washington, D.C. (November 6, 2013) Panelist, Tax Controversy Clinic, Maryland Volunteer Lawyers Service, Baltimore, MD (November 5, 2013) Conference Co-Chair, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17-18, 2013) Panelist, Relief from Joint and Several Liability, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2013) Panelist, Administrative Collections, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2013) Panelist, Closing Documents, Extensions and Qualified Offers, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2013) Presenter, Assessment and Collection of the FBAR Penalty, Mannes Greenberg Wednesday Tax Study Group, Baltimore, MD (October 2, 2013) Panelist, Criminal Tax Sentencing: Fairness and Deterrence, Villanova Law Review Norman J. Shachoy Symposium, Villanova, PA (September 27, 2013) Panelist, Ethical Issues Arising from Conflicts of Interest, Fall Meeting, Taxation Section, American Bar Association, San Francisco, CA (September 20, 2013) Presenter, Reporting Foreign Assets, Foreign Financial Accounts, and Cash Transactions- IRS 2013 National Tax Forum, Washington, D.C. (August ) Moderator, But It s Not My Fault! The Scope of the Reasonable Cause Defense and Good Faith Exception to Tax Penalties, NYU 5th Annual Tax Controversy Forum, New York, NY (June 7, 2013)

6 P a g e 6 Moderator, The Ethical Minefield: Practical Advice for Difficult Tax Practice Issues, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 17, 2013) Panelist, Preparing and Arguing Your Case in IRS Appeals, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 17, 2013) Panelist, How and When to Work with the Taxpayer Advocate, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 15, 2013) Moderator, Restitution and Civil Tax Issues in Sentencing, ABA Section of Taxation, Webinar (May 14, 2013) Moderator, Assisting Clients with the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy, May Meeting, ABA Section of Taxation, Washington, DC (May 11, 2013) Moderator, An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies, ABA Section of Taxation, Webinar (April 24, 2013) Panelist, Through the Looking Glass (Part III): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, ABA Section of Taxation, Webinar (April 10, 2013) Panelist, Careers in Tax Law, University of Baltimore, School of Law, Graduate Tax Program, Baltimore, MD (March 13, 2013) Panelist, Through the Looking Glass (Part III): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, Midyear Meeting, ABA Section of Taxation, Orlando, FL (January 25, 2013) Moderator, An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies, Midyear Meeting, ABA Section of Taxation, Orlando, FL (January 25, 2013) Panelist, Through the Looking Glass (Parts I and II): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, ABA Section of Taxation, Webinar (January 16, 2013) Instructor, Volunteer Income Tax Assistance (VITA) Military Training Program, Ft. Meade Army Base, Ft. Meade, MD (2012-present) Moderator, Restitution and Civil Tax Issues in Sentencing, ABA 29th Annual National Institute on Criminal Tax Fraud and 2d Annual National Institute on Tax Controversy, Las Vegas, NV (December 6, 2012) Moderator, Criminal Tax Workshop: The Basics, ABA 29th Annual National Institute on Criminal Tax Fraud and 2d Annual National Institute on Tax Controversy, Las Vegas, NV (December 5, 2012) Presenter, Tax Controversies in Divorce Issues for Every Client, 17th Annual Symposium on Family Law, American Academy of Matrimonial Lawyers, Maryland Chapter, Ellicott City, MD (November 12, 2012) Panelist, Civil Penalties on the International Front: Increasing Complexity and Peril for the Taxpayer, International Tax Enforcement Conference, ABA Section of Taxation and Tax Executives Institute, New York, NY (November 9, 2012) Panelist, Voluntary Disclosures Maryland and Beyond, Advanced Tax Institute, Baltimore, MD (November 8, 2012) Presenter, An Offshore Update Review of the 2012 OVDP, FBAR Requirements and FATCA, Tax Controversy Study Group, Maryland State Bar Association, Baltimore, MD (October 17, 2012) Presenter, IRS Examination Process, Virginia Society of Certified Public Accountants, Northern Chapter, Falls Church, VA (September 25, 2012) Panelist, Through the Looking Glass (Part I): Opting Out of the OVDI Penalty Structure What Happens Now?, Fall Meeting, ABA Section of Taxation, Boston, MA (September 14, 2012)

7 P a g e 7 Panelist, Evidentiary Issues in Tax Litigation, Fall Meeting, ABA Section of Taxation, Boston, MA (September 14, 2012) Panelist, Down the Rabbit Hole: The ABCs of Disclosure, ABA Section of Taxation, Fall Meeting, ABA Section of Taxation, Boston, MA (September 14, 2012) Presenter, Reporting Foreign Assets, Foreign Financial Accounts, and Cash Transactions- IRS 2012 National Tax Forum, New York, NY (August 30, 2012) Presenter, Examination Representation 101, IRS 2012 National Tax Forum, New York, NY (August 28, 2012) Panelist, But I Relied on My Accountant! The Scope of Reasonable Cause Defense to Penalties, NYU 4th Annual Tax Controversy Forum, New York, NY (June 15, 2012) Panelist, Understanding IRS Criminal Investigations, American Association of Attorneys-CPAs (AAA- CPAs), Capital Chapter, Baltimore, MD (June 5, 2012) Panelist, Tax Workshop, RSM McGladrey, Baltimore, MD (May 31, 2012) Moderator, Restitution and Civil Tax Issues in Sentencing, May Meeting, ABA Section of Taxation, Washington, DC (May 12, 2012) Panelist, Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There are Criminal Tax Issues, May Meeting, ABA Section of Taxation, Washington, DC (May 11, 2012) Panelist, What You Must Know About Tax Law Practice (That Your Law School or LLM Program May Not Have Taught You), May Meeting, ABA Section of Taxation, Washington, DC (May 10, 2012) Panelist, The Ethical Minefield: Practical Advice for Difficult Tax Practice Issues, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 4, 2012) Panelist, Preparing and Arguing Your Case in IRS Appeals, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 3, 2012) Presenter, Defending Tax Cases, White Collar Practice Seminar, Office of the Federal Public Defender and the Federal Bar Association, District of Delaware, Wilmington, DE (April 20, 2012) Panelist, Tax Controversy Training for Pro Bono Lawyers, Maryland Volunteer Lawyers Service (MVLS), Baltimore, MD (March 22, 2012) Panelist, Tax Fraud, Foreign Banks and Bankers, "Required Records Doctrine" and Forfeitures, 26th Annual Institute on White Collar Crime, Miami, FL (March 1, 2012) Panelist, Sentencing: How to Make the Best of a Bad Situation, Midyear Meeting, ABA Section of Taxation, San Diego, CA (February 18, 2012) Speaker, IRS Criminal Tax Roundtable, 28th Annual National Institute on Criminal Tax Fraud and 1st Annual National Institute on Tax Controversy, Las Vegas, NV (December 1, 2011) Panelist, Administrative Collection Procedures: Collection Due Process; Offers in Compromise and Installment Agreements; and Section 6672 Penalty Matters, How To Handle a Tax Controversy at the IRS & in Court: From Administrative Audit Through Litigation, American Law Institute and American Bar Association (ALI-ABA), Washington, DC (September 15, 2011) Panelist, Tax Practice Ethics for Preparers and Advisors: How To Handle a Tax Controversy at the IRS & in Court: From Administrative Audit Through Litigation, American Law Institute and American Bar Association (ALI-ABA), Washington, DC (September 15, 2011) Speaker, Recent Developments in Foreign Bank and Financial Account Reporting, ABA Section of Taxation, Webinar (June 14, 2011) Panelist, The Truth About IRS Collection Alternatives: What Works and What Doesn't, NYU 3d Annual Tax Controversy Forum, New York, NY (June 10, 2011)

8 P a g e 8 Presenter, Tax Crimes, National Seminar for Federal Defenders, Baltimore, MD (June 3, 2011) Panelist, Trust Fund Recovery Penalties From Investigation to Litigation, May Meeting, ABA Section of Taxation, Washington, DC (May 7, 2011) Presenter, Civil Tax Controversies, Anne Arundel County Bar Association, Annapolis, MD (March 22, 2011) Presenter, Voluntary Disclosures, Mannes Greenberg Wednesday Tax Study Group, Baltimore, MD (January 5, 2011) Panelist, Employment Tax Examinations, Maryland Association of Certified Public Accountants, Southern Maryland Chapter, La Plata, MD (December 9, 2010) Panelist, IRS Criminal Tax Roundtable, 27th Annual Criminal Tax Fraud Institute, San Francisco, CA(December 2, 2010) Panelist, Civil Tax Penalty Abatements-Fact or Fiction?, ABA Section of Taxation, Webinar (November 3, 2010) Panelist, The Nuts and Bolts of Handling a Pro Bono Tax Controversy - Part II, ABA Section of Taxation, Webinar (November 2, 2010) Panelist, IRS Voluntary Disclosure Practice, MSBA Taxation Section, Webinar (October 27, 2010) Panelist, The Nuts and Bolts of Handling a Pro Bono Tax Controversy - Part I, ABA Section of Taxation, Webinar (October 26, 2010) Panelist, Civil Tax Penalty Abatements-Fact or Fiction?, Fall Meeting, ABA Section of Taxation, Toronto (September 25, 2010) Presenter, Low Income Taxpayer Training, Maryland Volunteer Lawyers Service, Baltimore, MD (September 8, 2010) Panelist, Defense and Litigation of Penalties associated with Foreign Bank Account Reports and International Information Returns, Fall Meeting, ABA Section of Taxation, Chicago, IL (September 26, 2009) Recent Civil Cases In re Interstate Subpoena for Custodian of Records, Misc. Petition No M, Circuit Court for Montgomery County, MD (March 27, 2014) (successfully intervened in and obtained a protective order in response to a grand jury subpoena for a client s records in the possession of an accountant) United States v. Stahlnecker, Case No. 1:13-cv MJG, U.S. District Court for the District of Maryland (February 25, 2014) (successfully negotiated a settlement of a suit to reduce a federal tax lien to judgment, resulting in a reduction of assessed trust fund recovery penalties by approximately $400,000). Signature Flight Support Corporation v. Supervisor of Assessments for Anne Arundel County, Case No. 13-MI- AA-0579 (1-2), Maryland Tax Court (January 22, 2014) (successfully challenged the denial by the State Department of Assessment and Taxation and the Property Tax Assessment Appeals Board for Anne Arundel County ( PTAAB ) of an application for exemption from property tax on substantial improvements at the Thurgood Marshall Baltimore Washington International Airport, establishing that client was exempt as lessee of property owned by the State and used for a concession at a public airport) State of New York v. John Doe, Case No. C , Circuit Court for Anne Arundel County, MD (November 8, 2013) (successfully intervened in and negotiated a dismissal of an action to enforce a grand jury subpoena for a client s records in the possession of an accountant) United States v. Gill, Case No. 12-cv RDB, U.S. District Court for the District of Maryland (June 13, 2013) (successfully negotiated a settlement of an action to reduce a federal tax lien to judgment, and a dismissal of a complaint to foreclose property) Kareri v. Commissioner, Docket No , U.S. Tax Court (September 18, 2012) (negotiated stipulated Decision reducing proposed deficiency by more than $225,000 and reducing proposed

9 P a g e 9 penalty by more than $168,000 for tax years 2000 through 2003, and later successfully challenged the date on which the IRS posted a restitution payment, resulting in a refund of more than $138,000) Sharabi v. Commissioner, Docket No , U.S. Tax Court (September 7, 2012) (successfully challenged proposed tax deficiency of $191,989, resulting in no tax or penalties due) Annapolis Accommodations, Inc. v. Comptroller, Case No. 10-SU-OO-0606 (May 2, 2012) (successfully challenged Comptroller s assessment of penalty and interest with respect to sales tax assessment) Estate of Darrell L. Clark v. Commissioner, Docket No , U.S. Tax Court (April 9, 2012) (successfully challenged proposed tax deficiency of $110,923 and an accuracy-related penalty of $28,541, resulting in no tax or penalties due) Bresnahan v. Commissioner, Docket No , U.S. Tax Court (February 15, 2012) (successfully challenged proposed tax deficiency in the amount of $337,288 and a fraud penalty in the amount of $161,483.25, resulting in a final deficiency in the amount of $71,382, an accuracy-related penalty in the amount of $14,276.40). Mavroulis v. Commissioner, Docket No , U.S. Tax Court (February 8, 2012) (persuaded the IRS to grant innocent spouse relief for the full balance due for tax year 2003) Okiebisu v. Commissioner, Docket No , U.S. Tax Court (January 31, 2012) (successfully challenged proposed fraud penalty in the amount of $96,211.50) Edwards v. Commissioner, Docket No , U.S. Tax Court (January 18, 2012) (successfully argued insolvency exception to cancellation of indebtedness income, resulting in no deficiency) Shrader v. Commissioner, Docket No , U.S. Tax Court (August 9, 2011) (successfully challenged proposed tax deficiency of $20,144 and an accuracy-related penalty of $4,029, resulting in no tax or penalties due) Lokey v. Commissioner, Docket No , U.S. Tax Court (June 15, 2011) (persuaded the IRS to grant innocent spouse relief for the full balance due for tax year 2005) Grady, et al. v. Commissioner, Docket No S, U.S. Tax Court (June 14, 2011) (successfully challenged accuracy-related penalty, resulting in no penalty due) Solomon v. Commissioner, Docket No L, U.S. Tax Court (February, 2011) (successfully opposed IRS motion for summary judgment in response to petition for redetermination of levy action under IRC 6330) Samaco v. Commissioner, Abiog v. Commissioner and Ucol-Cobaria v. Commissioner, Docket Nos S, S and S, U.S. Tax Court (January, 2011) (successfully challenged accuracy-related penalties proposed against Filipino teachers who failed to report their teaching income earned from Baltimore City Public School System) Gunther v. Commissioner, Docket No , U.S. Tax Court (November, 2010) (successfully challenged proposed tax deficiencies in the amount of $120,083 and penalties in the amount of $46,603.50, resulting in final deficiencies in the amount of $2,530 and penalties in the amount of $52.50) Haddock v. Commissioner, Docket No , U.S. Tax Court (June, 2010) (successfully challenged proposed tax deficiencies for two tax years in the aggregate amount of $674,908 and fraud penalties in the aggregate amount of $479,254, resulting in a final deficiency for one year in the amount of $67,786, a negligence penalty in the amount of $9, and an overpayment in the amount of $21,824) Recent Criminal Tax Cases Represented individual investigated for filing false income tax returns resulting in a loss of more than $700,000. Client charged with a single violation of 26 U.S.C. 7206(1) resulting in an advisory Guideline range of 24 to 30 months. In September, 2014, persuaded the court to grant a downward variance, resulting in sentence of probation with the condition of 12 months of home detention.

10 P a g e 10 Represented individual investigated for filing false income tax returns. Negotiated a misdemeanor plea to a single count of 26 U.S.C and in May, 2014, successfully argued for a probationary sentence. Represented individual investigated for embezzlement and filing false income tax returns and amended income tax returns over a twelve year period. Negotiated a two-count plea to violation of 18 U.S.C and 26 U.S.C In April, 2013, successfully challenged government s argument against grouping, resulting in a reduced advisory Guideline range of 27 to 33 months, and persuaded to court to grant downward variance, resulting in a 15-month sentence with a recommended designation to a minimum security satellite camp. Represented individual investigated for failing to file foreign bank account reports and filing false income tax returns resulting in a loss of more than $800,000. Client charged with a single violation of 26 U.S.C resulting in an advisory Guideline range of 24 to 30 months. In February, 2013, persuaded to court to grant downward variance, resulting in sentence of a year and day, with a recommendation for direct placement to a local residential reentry center (formerly referred to as community confinement or halfway house). Represented individual investigated for structuring and failing to file income tax returns for 10 years. Negotiated plea to single violation of 26 U.S.C resulting in an advisory Guideline range of months. In November, 2012, persuaded to court to grant downward variance, resulting in sentence of eight months in a minimum security satellite camp. Represented individual investigated for structuring and failing to file income and employment tax returns for several related entities over more than five years. Negotiated plea to single violation of 26 U.S.C Successfully challenged U.S. Probation Office s position that client engaged in sophisticated means, resulting in an advisory Guideline range of months. In November, 2012, persuaded to court to grant downward variance, resulting in sentence of 13 months in a minimum security satellite camp. Represented individual investigated for structuring and filing false individual and corporate income tax returns over more than five years. Negotiated plea to single violation of 26 U.S.C resulting in an advisory Guideline range of months. In November, persuaded to court to grant downward variance, resulting in sentence of a year and a day in a minimum security satellite camp. Represented individual and his related entities investigated for failure to file income tax and employment tax returns and pay related tax over a 7-year period in violation of 26 U.S.C and failure to properly withhold under 26 U.S.C. 7206(1). Negotiated plea to two counts of willful failure to file (misdemeanors), with an advisory Guideline range of 18 to 24 months. In October, 2012, persuaded to court to grant downward variance, resulting in sentence of 10 months in a residential reentry center (formerly referred to as community confinement or halfway house) , v. 2