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JEFFREY M. WONG
jeffrey.wong@greenemarkley.com
EDUCATION
& PROFESSIONAL QUALIFICATIONS
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B.A. Reed College, 1978 (Reed College Award for Academic Excellence,
1978);
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J.D. University of Oregon, 1984.
Mr.
Wong spent 14 years working for the Internal Revenue Service as
a senior trial attorney in the Office of the Chief Counsel for the
Internal Revenue Service and as a Special Assistant U.S. Attorney
in the District of Oregon. During that time he gained vast knowledge
of the federal tax laws and the administration of taxes in bankruptcy.
From 1991 to 1998, Mr. Wong was the IRS' primary bankruptcy litigator
in Oregon and the primary advisor to the Oregon IRS Collection Division.
He has been in private practice with Greene & Markley since
1998. Mr. Wong has taught and written on a wide variety of tax and
tax-related subjects for the IRS, the Oregon State Bar, the Oregon
CPA and other tax professional societies.
MEMBERSHIPS
& HONORS
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Member: United States Tax Court; United States District Court
for the District of Oregon; Multnomah Bar Association; Oregon
State Bar Association; Debtor/Creditor and Taxation Sections
of the Oregon State Bar
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Honors: IRS Chief Counsel Manager Awards: 1985, 1986, 1987,
1989, 1990, 1993, 1994, 1995, 1996. Western Region Fayette Taylor
Award for Excellence in General Litigation, 1991
PRACTICE EMPHASIS
Mr. Wong focuses his practice in civil tax determination, tax
collection controversies, bankruptcy and tax planning.
TEACHINGS
- "Resolving Tax Collection Controversies."
Continuing Professional Education Seminar for the Oregon Society of Public Accountants and Oregon Society of Licensed Tax Consultants, Summer 2003.
- "Bombs, Alchemy, Hand-Offs and Perishable Losses: Tax Planning
Opportunities and Pitfalls in Bankruptcy Cases."
Continuing Legal Education Seminar for the Oregon and Washington
Bars sponsored by the Northwest Bankruptcy Institute, Seattle,
Washington, April, 2003.
- "Resolving
Tax Collection Controversies."
Continuing Professional Education Seminar for the Oregon Society
of Certified Public Accountants, November, 2002.
- "Resolving
Tax Collection Controversies." Continuing Professional
Education Seminar for the Oregon Society of Certified Public
Accountants, September, 2002.
- "Dealing
with the Tax Man." Continuing Legal Education seminar
on "Advising Troubled Businesses in Oregon"
for the Oregon State Bar, May, 2002.
- "The
Taxation of Damage Awards." Continuing Legal Education
seminar on "Broad Brush Taxation" for the Oregon State
Bar, October, 2001.
- "The
Private Practitioner's Perspective on IRS Appeals."
Continuing Professional Education Seminar for the IRS Appeals
Offices in Alaska, Washington, Oregon, Northern California,
and Hawaii, October, 2001.
- "Tax
Issues in Bankruptcy." Continuing Professional
Education Seminar for the Oregon Society of Tax Consultants
Convention, August, 2001.
- "Tax
Issues for the Small Business."
Continuing Legal Education Seminar entitled "Survivor:
A Small Business in Chapter 13," for the Oregon State Bar
Debtor-Creditor Section, July, 2001.
- "Tax
Evasion and Bankruptcy." Continuing Professional
Education for IRS Special Enforcement Program Revenue Agents
from the states of Alaska, Hawaii, Oregon, and Washington, September,
1999.
- "Lien
Priorities and Bankruptcy." Continuing Legal Education
seminar for the Multnomah County Bar Association, Oregon, February,
1999.
- "Paper,
Rock, Scissors: Who Wins?" Continuing Legal Education
seminar on lien priorities for the Debtor-Creditor Section of
the Oregon State Bar, August, 1998.
- "The
Willful Evasion of Tax Exception to Discharge in Bankruptcy."
Chief Counsel, hour-long presentation on BC § 523(a)(1)(C)
broadcasted nationally on IRS closed-circuit TV. Washington
DC, 1997.
- "General
Litigation." Chief Counsel sponsored week-long
training program for attorneys on fundamental concepts of tax
assessment and collection. Nashville, 1997.
- "Bankruptcy."
Chief Counsel sponsored week-long training program for attorneys
on bankruptcy and tax issues arising therein. Ft. Lauderdale,
1996.
- "Bankruptcy
Practice Seminar." Chief Counsel sponsored week-long
training program for Special Assistant US Attorneys focusing
on practice for the IRS before the bankruptcy court. Salt Lake
City, 1994.
- "Federal
Tax Claims." Hour-long segment on tax liens and
their priorities, given as part of the Oregon Law Institute
sponsored Continuing Legal Education on "Governmental
Claims In and Out of Bankruptcy." Wilsonville, May,
1993.
WRITINGS
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"The IRS Reorganization: An Agency in Crisis."
Article published in the Taxation Section Newsletter for the
Oregon State Bar, February, 2003.
- "Spousal
Relief from Joint Tax Liability." Article published
in the Debtor-Creditor Section Newsletter for the Oregon State
Bar, Spring, 2001.
- "Joint
or Separate Income Tax Returns for the Debt-Troubled Household."
Article published in the Debtor-Creditor Newsletter for the
Oregon State Bar, Winter, 2001.
- "IRS
Offers in Compromise: A Kinder, Gentler Alternative to Bankruptcy."
Article published in the Debtor-Creditor Section Newsletter
for the Oregon State Bar, Winter, 2000.
- "The
New IRS Collection Due Process Appeal Process."
Article published in the Debtor-Creditor and Taxation Sections
Newsletters for the Oregon State Bar, Fall, 1999.
- "Tax
Aspects of Bankruptcy."
(Parts III and IV thereof); Chapter 5 of the Oregon State Bar
handbook on Bankruptcy Law, 1999 Revision.
- "Federal
Tax Lien Priority."
OSB Debtor-Creditor Newsletter, Summer, 1999.
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"An Overview
of Tax Administration."
OSB Debtor-Creditor Newsletter, Spring, 1999.
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"Tax Lien Priorities" and "The Treatment
of Tax Claims in Bankruptcy." Two Chapters of the Continuing
Legal Education materials on competing lien priorities
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"Paper, Rock, Scissors: Who Wins?" OSB Debtor-Creditor
Section Meeting, August: 1998.
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"The Willful Evasion of Tax Exception to Dischargeability
Under Bankruptcy Code Section 523(a)(1)(C)."
IRS deskbook on criteria for tax evasion cases in bankruptcy.
Coauthored in 1997 with five members of a national task force.
- "Federal
Tax Claims." Chapter 5 of the materials published by
the Oregon Law Institute for a 1993 CLE on "Governmental
Claims In and Out of Bankruptcy." A general discussion
of tax liens and their prioities against other creditors.
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"The After-Acquired Property Rule with Federal Tax Liens."
OSB Debtor-Creditor Section Newsletter, Spring, 1992.
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