Tax Disputes and Litigation
Michael represents taxpayers in all stages of tax disputes, including examinations, administrative appeals and litigation. He has experience representing clients in federal and state tax disputes.
At the state level, Michael has experience with resolving and litigating disputes involving statutory and constitutional nexus issues, state level research and experimentation credits, apportionment, and sales and use taxes
At the federal level, Michael has litigated complex corporate tax matters in the United States Tax Court, including debt and equity characterization of intercompany financing transactions, transfer pricing, and the research and experimentation credit.
Complex Business and M&A Disputes
Michael advocates for clients in post-M&A transaction disputes involving purchase price adjustments, indemnification claims, and earn-out disputes. Michael has litigated M&A related matters in state and federal courts as well as domestic and international arbitration forums.