Partnership Representative Professionals

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Charles M. Ruchelman

Building on his experience with the TEFRA partnership provisions, Mr. Ruchelman has spent a significant amount of time studying, speaking on, and writing about the new IRS tax and collection procedures relating to partnerships and limited liability companies that were recently enacted under the Bipartisan Budget Act of 2015. Since enactment of the new statute, Mr. Ruchelman has spoken on panels with a Tax Court judge, government officials from the Treasury Department and IRS Office of Chief Counsel, as well as other practitioners before the American Bar Association, American Institute of CPAs, DC Bar Association, and Bloomberg/BNA.

 “a great litigator, a good strategic thinker and an excellent advocate” – Chambers USA

Mark D. Allison

Mr. Allison’s practice involves complex federal, state, and cross-border tax controversy and litigation matters; related civil, criminal, and regulatory proceedings; and internal investigations. He represents multinational corporations, financial institutions, and high net worth individuals and professional athletes in proceedings before the Internal Revenue Service, the U.S. Department of Justice, the U.S. Attorneys’ Office, and other government regulators, with substantial industry experience in financial services, healthcare, utilities and infrastructure.

“‘the firm is recognized for its clear strength in tax controversy’ and . . . is also present in New York, where the ‘very experienced’ Mark Allison is the key partner” – 2014 Tax Directors Handbook

Rachel L. Partain

In the tax controversy arena, Ms. Partain provides skilled counsel to clients involved in examinations, appeals, tax and bankruptcy litigation, collections, compliance reviews, and internal investigations. Moreover, she partners with clients to develop policies and procedures that help reduce their risks and enhance their business operations.

Ms. Partain routinely appears before the Internal Revenue Service, the Department of Justice, and other government regulators to advocate for her clients’ best interests.

“she has always impressed me with her ability to convey complex tax concepts in a clear and understandable manner without overlooking the needed details” – Martindale Hubbell Peer Review

Elizabeth J. Stevens

Ms. Stevens has represented partnerships across a variety of industries in tax and commercial matters and has assisted clients with the drafting, negotiation, and revision of partnership and LLC operating agreements.  Having gained an appreciation for the complexity of the TEFRA partnership provisions in her work at the U.S. Tax Court, she has closely followed the new partnership and LLC audit and collection procedures introduced by the Bipartisan Budget Act of 2015 and subsequent regulatory guidance, and she contributed to the American Bar Association Tax Section’s comment letter on the 2015 legislation.