Gray Proctor

Overview

Gray is a board-certified appellate specialist and one of fewer than one percent of active Florida Bar members to hold that designation. He focuses his practice on federal appellate litigation, with particular depth in tax controversy appeals and APA-based challenges to federal agency action. He is admitted to practice in the Tax Court, in district courts in Florida and Georgia, in the First through Sixth and Eleventh Circuit Courts of Appeals, and in the Supreme Court.

Gray brings a combination that is genuinely difficult to find: the procedural command of a dedicated appellate advocate with three federal clerkships, and the substantive fluency of a practitioner embedded in high-stakes tax litigation every day. His published work on SEC v. Jarkesy and its implications for tax penalty procedure has been cited by courts and practitioners as a leading treatment of the administrative law revolution reshaping federal regulatory enforcement.

Gray's appellate practice spans the full arc of federal tax controversies — from preserving the best constitutional and statutory challenges in the U.S. Tax Court, to coordinating appellate strategy as cases move to the circuit courts, to briefing and oral advocacy in the circuits and the Supreme Court. He also serves as appellate co-counsel to trial firms handling matters outside tax, particularly cases turning on federal agency action and APA procedure, where his background adds a layer of expertise that most appellate generalists cannot offer.

Gray graduated from Vanderbilt University Law School, where he received the book award for criminal procedure. He served as a federal law clerk in three courts — the Southern District of Texas, the Eastern District of Virginia, and the U.S. Court of Appeals for the Fourth Circuit — before building his appellate practice. He has been board certified in appellate practice by the Florida Bar since 2021, is AV Preeminent rated by Martindale-Hubbell, and has been recognized as an elite appellate practitioner by Florida Trend magazine.

Beyond tax, Gray maintains an active criminal appellate practice. He accepts CJA appointments in the Sixth and Eleventh Circuits, has represented clients in death row clemency proceedings, and earlier in his career contributed to the successful reversal of a high-profile Tennessee murder conviction. Gray also accepts clients on appeal of civil matters outside of tax, including commercial litigation, insurance coverage, and other matters.