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Phil is a Managing Director for Tax Practice Policy & Quality (“TPQ”) in our Philadelphia office. The bulk of Phil’s tax career has concentrated on IRS Practice and Procedure. For over seven years he served as a trial attorney in the Office of Regional Counsel or District Counsel, IRS – four of them as a “Special Trial Attorney” based in Philadelphia where he assisted and represented IRS in large corporate civil tax examinations, appeals and litigation. He led trials of precedent-setting cases in the financial service industry and participated in significant reported and unreported decisions in cases involving retail, pharmaceutical, chemical, automobile, entertainment and communications industries.
As the first Director of a global accounting firm’s Mid-Atlantic Area IRS Practice and Procedure services, Phil worked with many of the Fortune 500 taxpayers in the region in resolving their federal tax controversies and managing their federal tax risks. Phil was involved in ground-breaking cases using techniques such as the IRS pilot program for “Fast Track Settlement.”
Through his professional practice and his long-standing commitment to the ABA Tax Section, including chairing the Administrative Practice Committee, Phil has maintained good, close relationships with IRS LB&I executives, Office of Chief Counsel attorneys, and numerous management, examination and appeals personnel throughout the nation.
Prior to joining the firm, Phil was a shareholder in the international law firm of Greenberg Traurig, a Director of Tax Controversy and Risk Management Services Practice at Ernst & Young, and a Special Trial Attorney in the Office of the Chief Counsel at the IRS.
Phil continues to focus his career on representing and advising clients in federal, state and international tax issues before tax authorities and courts.