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Tax Controversy Group

Greene & Markley boasts unique expertise in the field of taxation. Jeff Wong served as an attorney with the Internal Revenue Service’s Office of Chief Counsel for nearly fourteen years. During most of the 90's, he shouldered primary responsibility for legal advice to the Oregon IRS Collection Division, and represented the IRS in most of its litigated bankruptcy controversies as a Special Assistant U.S. Attorney. Stephen T. Boyke has practiced for fifteen years in the bankruptcy/taxation area, providing solution-orientated advice to business and individual clients alike. A thorough understanding of the interplay between bankruptcy and tax laws is often neccessary to avoid numerous pitfalls which can appear without careful planning. Judy Killian served for ten years as an IRS Revenue Agent in Oregon. Most of Judy’s government career was spent in the IRS’ prestigious Special Enforcement Program, where she specialized in the detection and proof of unreported income. Together, they offer clients unique insight into the thinking and case development processes of the IRS, audit and other risks associated with tax and other transactions, and the most efficient means of resolving a tax controversy.

The Greene & Markley tax practice group can service most types of controversies that arise with the federal and Oregon taxing authorities. This includes audits and litigated disputes over the amount of tax due before the federal and state Tax Courts, and collection controversies where a client faces tax liabilities that cannot be conveniently paid. Greene & Markley is one of the few firms in Oregon (if not the only firm), that offers equal expertise in both bankruptcy and non-bankruptcy solutions to a tax problem. The tax practice group can competently prepare returns and financial statements demanded by a taxing authority. It can efficiently service many types of cases where expertise can be difficult to find, such as taxation in bankruptcy and insolvency, tax lien priorities, jeopardy assessments, transferee liabilities, estate tax liens, and other extraordinary IRS enforcement actions.

The tax practice group generally does not service criminal controversies, pension plans, international tax, or the income tax aspects of corporate reorganizations and exempt organizations.

Members who work in this practice area:

Jeffrey M. Wong

Heather H. Vogl

 

Articles:

Federal Tax Lien Priority

Stephen T. Boyke

Donald H. Grim

 

 

An Overview of Tax Administration and Tax Liens