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JEFFREY M. WONG
jeffrey.wong@greenemarkley.com

EDUCATION & PROFESSIONAL QUALIFICATIONS

  • B.A. Reed College, 1978 (Reed College Award for Academic Excellence, 1978);
  • 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

  • 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
  • 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
  • "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.
  • "An Overview of Tax Administration." OSB Debtor-Creditor Newsletter, Spring, 1999.
  • "Tax Lien Priorities" and "The Treatment of Tax Claims in Bankruptcy." Two Chapters of the Continuing Legal Education materials on competing lien priorities
  • "Paper, Rock, Scissors: Who Wins?" OSB Debtor-Creditor Section Meeting, August: 1998.
  • "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.
  • "The After-Acquired Property Rule with Federal Tax Liens." OSB Debtor-Creditor Section Newsletter, Spring, 1992.