Admitted
1979, Texas; 1991, U.S. Tax Court; 1993, District of Columbia
Law School
University of Texas at Austin, J.D., with honors, 1979
Law School Graduation Year
1979
College
Calvin College, B.A., 1972
Memberships
The Bar Association of the District of Columbia (Section of Taxation); Federal (Section of Taxation) and American (Section of Taxation) Bar Associations; International Fiscal Association (USA Branch).
Biographical
Recipient, Chief Counsel Award for Outstanding Performance. Author: U.S. Rules Pertaining to Positions Taken by a Taxpayer in Computing U.S. Income Tax Liability, Tax Management International Forum (March 2003); Five Major Deficiencies with Respect to Taxation of Business Entities, Tax Management International Journal (August 2002); The United States Should Not Tax U.S. Corporations on Their Worldwide Income, ABA Section of Taxation Newsletter (Fall 2001); The U.S. Tax Code and Reality: Improving the Connection, Tax Notes International (October 1999); The Taxation of Foreign Income from 1909 to 1989: How a Tilted Playing Field Developed, Tax Notes (June 1989, with William P. McClure); The Final Foreign Tax Credit Regulations, Taxes--The Tax Magazine (August 1984). Co-Author, with H. David Rosenbloom, Taxes Covered by Section 960(a)(3), Tax Management International Journal (February 2002). Former Attorney-Advisor, IRS Office of Chief Counsel, Legislation and Regulations Division (International Branch), Washington, D.C. Principal author of the final foreign tax credit regulations under Sections 901/903; Negotiator on income tax treaties with Sweden, Denmark, and The Netherlands Antilles. Member: J. Edgar Murdock American Inn of Court (U.S. Tax Court), 1994-1997; The National Press Club.