Prior to joining private practice, Stephen held positions as a trial attorney with both the Tax Division and Civil Division of the United States Department of Justice, where he was hired through the Attorney General’s Honors Program and received the Tax Division’s Outstanding Attorney Award. Immediately after law school, Stephen served as a law clerk for the Hon. J. Daniel Breen of the United States District Court for the Western District of Tennessee. Stephen regularly draws upon the skills and knowledge that he gained from his government experience to assist clients in resolving their tax disputes efficiently and fairly. A sample of Stephen’s representative matters include:
- Representing an individual under criminal investigation by the United States Department of Justice Tax Division. During the investigation, the government issued a subpoena to a law firm that provided the client with both legal and accounting advice, leading to a multi-year privilege dispute that culminated in the Supreme Court of the United States granting certiorari in the matter, In re Grand Jury (Case No. 21-1397) (dismissed as improvidently granted after oral argument).
- Representing an individual under criminal investigation for promotion of an alleged tax shelter.
- Providing pre-litigation analysis for a large corporation on a potential multi-billion-dollar excise tax refund claim.
- Counseling large corporations on tax-related bankruptcy procedures, including tax claim priority and dischargeability of tax liabilities.
- Representing individuals and corporations under audit on issues involving substantiation of capital losses, eligibility for the qualified small business stock exclusion, and worker classification.
- Navigating clients through federal and state voluntary disclosure programs for issues including tax return non-filing, failing to report taxable income, and misclassifying workers for employment tax purposes.
- Representing clients in civil tax disputes before federal courts including a refund matter involving procedures for claiming foreign tax credits, defending a client in a suit to reduce estate tax liabilities to judgment and to hold the client – an estate executor – personally liable under the federal priority statute, and seeking to quash a summons that the IRS issued after receiving a foreign nation’s treaty request to gather the client’s United States banking records.
Stephen received his B.A. with High Distinction from the University of Michigan and his J.D. from Vanderbilt University Law School, where he served as a managing editor of the Vanderbilt Journal of Entertainment and Technology.