Practice Description
Concentration in IRS Administrative Practice and U.S. Tax Court Litigation.

Notable Cases and Results
Estate of Robert H. Lurie v. Commissioner, T.C.M. 2014-19. Lost and appealed to Seventh Circuit.

Investment Research Associates, Ltd. v. Commissioner, T.C.M. 1999-407. Lost and appealed to Fifth and Eleventh Circuits and to U.S. Supreme Court, which reversed.

Universal Manufacturing Company v. Commissioner, T.C.M. 1994-367. Won.

Bar Admissions
Illinois Bar
California Bar
Missouri Bar
United States Tax Court
General Bar and the Trial Bar of the Northern District of Illinois
United States Court of Appeals for the Fifth, Seventh and Eleventh Circuits
United States Court of Federal Claims
United States Supreme Court

Year of Birth
1948

Law School
J.D., University of Missouri Law School
Law School Honors/Involvement
Undergraduate School
University of Missouri, B.S. in Business Administration

Employment History
Office of Regional Counsel, Internal Revenue Service
Office of District Counsel, Internal Revenue Service
Silets and Martin, Ltd.

Bar/Professional Association Involvement
Illinois State Bar Association
Chicago Bar Association
....— Section of Federal Taxation
American Bar Association
....— Federal Taxation Section
....— Court Procedure Committee
State Bar of California
....— Tax Section

Community Involvement
Adjunct Professor, Federal Civil Tax Procedure, LL.M. Program in Tax Law,
The John Marshall Law School

Published Legal Writing
“The Fallout After Ballard,” Journal of Tax and Procedure, 2005

Legal Lectures
“An Overview of IRS Examinations, Administrative Appeals and Tax Court Litigation,” Chicago Bar Association, 2000

“Representation of Promoters and Preparers in Tax Shelter Investigations,”
ABA Tax Section, 2003

“Privilege and Work Product in the Context of Tax Litigation, Lessons from the Trenches,” ABA Tax Section - CLE, 2004

“ What Remains of the Attorney-Client and Accountant-Client Privilege in Tax Planning?” Arizona Bar Convention, 2004

“IRS Practice & Procedures,” 2005 Tax Conference, Illinois CPA Foundation