Partner, Crowell & Moring, LLP. Twenty-five years of experience handling tax litigations and controversies for multi-national Energy, Retail, Technology and other businesses, including transfer pricing, foreign tax credits, and partnerships. Administrative practice includes IRS audits, Appeals, APAs, and Competent Authority proceedings.
Editor of The Transfer Pricing Answer Book (Practising Law Institute);
Co-author of BNA Tax Management Portfolio No. 891-2nd, “Transfer Pricing: Audits, Appeals, and Penalties”;
Adjunct Professor, Transfer Pricing, Selected Topics, Georgetown Law Center;
Law Clerk to Hon. Frank M. Johnson, Jr., United States Court of Appeals for the 11th Circuit (1989-1990);
Trial Attorney, U.S. Department of Justice, Tax Division (1990-1995).