Education
Boston University School of Law, LLM, Tax
University of Connecticut School of Law, JD
Union College, BA
Experience
- Drafted tax opinions and provided tax advice for a complex development finance transaction involving dozens of funding sources, and numerous federal and state tax credits, including New Markets, Historic Tax Credits, Solar ITC and LIHTC.
- Obtained an abatement of assessed corporate income tax at the Massachusetts Department of Revenue Office of Appeals, successfully arguing for the correct apportionment of income for 40 Act mutual funds vs. non-40 Act mutual fund clients.
- Obtained full abatement of contested taxes and penalties in US Tax Court litigation involving the Qualified Business Income (QBI) deduction.
- Assisted numerous business clients in reducing FIN 48 tax exposure for unpaid prior year taxes, interest and penalties through state tax voluntary disclosure agreements, limiting the number of years required to be filed and obtaining waivers of penalties.
Admissions
Massachusetts, 2005
United States Tax Court, 2009
Vermont, 2025
Clerkships
Law Clerk to the Justices, Superior Court of Massachusetts, 2005-2006
Law Clerk – Massachusetts Appellate Tax Board (ATB), 2009
Memberships & Activities
American Bar Association – Tax Section
Vermont Bar Association
Community Involvement
Vermont Department of Taxes Commissioner’s Tax Administration Advisory Board – Member
Publications
- Massachusetts Supreme Judicial Court invalidates ‘millionaire’s tax’ ballot question as unconstitutional – EY Tax Alert I.D. No. 2018-0208
- US. Supreme Court Denies Cert of First Marblehead II, Massachusetts Supreme Judicial Court finding that Financial Institution Excise Tax meets Wynne internal consistency test upheld – EY Tax Alert I.D. No. 2017-0447
- New York Tax Appeals Tribunal holds application of Article 33 Tax on Insurance Corporations on alien insurance company violated nondiscrimination provisions of the US-German tax treaty – EY Tax Alert I.D. No. 2017-2097
- New York State Appellate Division find HMO not ‘doing an insurance business’ is subject to New York City’s General Corporation Tax – EY Tax Alert I.D. No. 2018-0208