Jamie represents clients in IRS audits, before the IRS Office of Appeals, and in tax litigation in the U.S. Tax Court, the U.S. Court of Federal Claims, and other federal courts. Clients appreciate his “strategic approach” and “creativity” in pursuing favorable outcomes as early in the process as possible.
Jamie originally joined IPB in 2003 as an associate. From 2006 to 2013, he was a trial attorney with the Tax Division of the U.S. Department of Justice, where he was lead counsel for the government in over 100 civil tax cases, and he received two Outstanding Attorney awards. Jamie has served as Chair and Vice-Chair of the D.C. Bar Tax Audits and Litigation Committee.
Jamie's representations have involved many areas of federal tax law including transfer pricing, civil tax penalties, valuation, summonses, the taxation of financial instruments, the timing of income and deductions, corporate reorganizations, deductions for worthless investments, the substance-over-form and economic substance doctrines, worker classification, and loss limitations. To learn more about the results Jamie has obtained for clients, please click on the “Experience” tab.
Harvard Law School, 2003, J.D.
University of St. Andrews, 2000, M.A., Mathematics-Philosophy, First Class Honours
Bar & Court Admissions
District of Columbia (2005)
Massachusetts (inactive) (2004)
U.S. Tax Court
U.S. Court of Federal Claims
U.S. District Court for the District of Columbia
U.S. Courts of Appeals for the Sixth and Eleventh Circuits
U.S. Supreme Court
Memberships & Affiliations
D.C. Bar, Taxation Community: Steering Committee member (2017- present); Committee on Tax Audits and Litigation, Chair (2016-2018); Community Outreach Coordinator (2017-present)
American Bar Association, Section of Taxation, Transfer Pricing Committee, Member
Federal Bar Association, Section on Taxation, Member
- Representing manufacturing company in U.S. Court of Federal Claims litigation.
- Represented insurance marketing company in U.S. Tax Court worker classification (employee/independent contractor) litigation in which IRS proposed to assess $3.6 million in additional payroll taxes. IRS conceded in response to motion for summary judgment.
- Represented private equity fund in TEFRA partnership audit contesting $11 million in bad debt deductions. IRS made no adjustments.
- Represented U.S. subsidiary in transfer pricing audit proposing $4 million adjustment to prices charged by foreign parent company for products imported into the U.S. IRS made no adjustments.
- Represented investment management company in IRS audit of international tax and transfer pricing issues raised by transfer of portfolio to Irish company. IRS made no adjustments.
- Co-counsel for taxpayer in 2015 Tax Court trial involving economics of publishing industry.
- Co-authored taxpayers' successful briefs in Wright v. Comm'r, 809 F.3d 877 (6th Cir. 2016). Court of Appeals held that under plain meaning of Internal Revenue Code, mark-to-market tax accounting applies to over-the-counter options on major foreign currencies.
- Drafted Tax Court petition contesting alleged $3.8 million deficiency based on IRS's finding that merger did not qualify as tax-free reorganization, and therefore surviving entity did not succeed to net operating losses of over $33 million. IRS conceded in answer to petition.
- Drafted memorandum for IRS auditors regarding $30 million issue arising from interaction between foreign sales corporation ("FSC") regime and alternative minimum tax ("AMT"). IRS made no adjustments.
- Co-counsel in Court of Federal Claims trial regarding $42.6 million refund contested by IRS using economic substance and substance-over-form doctrines.
News & Events
- IPB Alert: Notice 2019-09 and Section 4960 | 04.02.2019
Speeches & Presentations
- "Managing Complex IRS Audits of Midsize Business Taxpayers," CPAacademy.org, October 11, 2018
- "Practical Privilege Issues," Tax Executives Institute, Audits & Appeals Seminar, May 1, 2018
- “Managing Complex IRS Audits - Impact of LB&I Reforms," Tax Executives Institute, Region III, June 23, 2017
- "Preventing Compelled Disclosure of Sensitive Tax Analysis," Tax Executives Institute, New Jersey Chapter, February 24, 2017
"Guide to Civil and Criminal Tax Penalties," Lexis Practice Advisor (August 2018)
"Tax Court Litigation: Basics," Lexis Practice Advisor (August 2018)
"Defending Transfer Pricing Audits Under the IRS's New Roadmap," Tax Notes (April 28, 2014)
"Coming Conflicts: Proposed U.S. Transfer Pricing Services Regulations and the Treatment of Intangibles," 6 Derivatives and Financial Instruments No. 5 (September 30, 2004)