Attorney Profile

Areas of Practice

• Taxation Law
• Appeals from Audits, Commissioner's Orders and Other Actions of Tax Authority
• Applications for Certificate of Discharge, Release and Subordination of Tax Lien
• Audits
• Collection Due Process Appeals
• Dischargeability of Taxes in Bankruptcy
• Employment Taxes
• Freedom of Information Act Requests (FOIA)
• Independent Contractors v. Employee Determinations (Conflicts with the Minnesota
• Department of Employment and Economic Development)
• Innocent Spouse/Injured Spouse
• Installment Agreements
• Installment Payment Plans
• Officer Liability for Unpaid Sales, Employment and Unemployment Taxes
• Offer in Compromise
• Refund Claims and Suits for Refunds
• Requests for Abatements of Tax, Interest and Penalties
• Sales & Use Taxes
• Seizures & Sales by the Tax Authorities
• Successor Liability
• Tax Levies
• Tax Liens
• Tax Litigation, Federal and State Courts
• Trust Fund Recovery Penalties

Certification/Specialties

• Public Accountant, Minnesota, 1987

Bar Admissions

• Minnesota, 1978
• U.S. District Court District of Minnesota
• U.S. Court of Appeals 8th Circuit
• U.S. Court of Federal Claims
• U.S. Supreme Court
• U.S. Tax Court

Education

• Harvard University Law School, Cambridge, Massachusetts, 1978
  J.D.
  
  
• University of Minnesota, 1975
  B.A., B.S
  
  

Published Works

• When Is A Penalty Not A Penalty: Internal Revenue Service Trust Fund Recovery Assessments, MNCPA Footnote Magazine, 1995
• IRS Survival Guidelines: New Rules on Installment Payment Agreements, MNCPA Footnote Magazine, 1996
• Penalty, 1996
• Penalty, 1994

Classes/Seminars Taught

• Adjunct Professor, Master of Business in Taxation Program, University of Minnesota, 1989 - 1992
• Speaker, Internal Revenue Service Collection Procedures, 1993
• Speaker, Representing A Taxpayer During An IRS Audit, 1993
• Speaker, 100% Payroll Tax Penalty: Who Can Be Held Responsible, MNCPA, 1995
• Speaker, Internal Revenue Service Audit Developments, MNCPA Annual Tax Conference, 1995
• Speaker, Internal Revenue Service Collection Procedures, MEGA Conference, May 30, 1996
• Speaker, How to Handle a Case in Tax Court (Federal and State) Taxpayer's Attorney's Perspective, Minnesota Institute for Legal Education (MILE), 1996
• Speaker, Internal Revenue Service Collection Procedures, Current Audits and One Hundred Percent Penalties by Mark Pridgeon and Saul Bernick, MNCPA Annual Tax Conference, 1996
• Speaker, Handling A Criminal Investigation Division Investigation, Hennepin County Bar Association, November 8, 1999
• Speaker, Ten Classic Court Cases With Lasting Impact, 1999
• Speaker, Tax Law Changes, 1999
• Speaker, Recent Developments in Federal Tax Controversies, Hennepin County Bar Association, September 11, 2000
• Speaker, Representing Your Clients With Tax Controversies Before the Tax Authorities, MSBA's 60th Annual Tax Institute, November 14, 2000
• Speaker, You Said Avoidance, I Say Evasion... Issues in Criminal Tax, MSBA's 61st Annual Tax Institute, November 12, 2001
• Speaker, Recent Developments in Federal Tax Controversies, Hennepin County Bar Association, October 13, 2003
• Speaker, Tax Developments, Jim Stanko, Honeywell, February 23, 1999

Professional Associations and Memberships

• Hennepin County Bar Association
  Member
  
  
• Minnesota State Bar Association
  Member
  
  
• American Institute for Certified Public Accountants
  Member
  
  
• Minnesota Society of Certified Public Accountants
  Member
  
  

Past Employment Positions

• District Counsel's Office for the Internal Revenue Service, Chicago, Attorney, 1978 - 1979
• District Counsel's Office for the Internal Revenue Service, St. Paul, Attorney, 1979 - 1985
• Ernst & Whinney, Manager and Senior Manager, 1985 - 1988
• Larson, Allen, Weishair & Co., Manager, 1989 - 1990
• Regan & Pridgeon, Partner, 1990 - 1992

Birth Information

• May 6, 1953, Dallas, Texas, United States of America