Career Overview
Current Focus: joined Applegate & Thorne-Thomsen in 2001. I am the chair of the Firm’s Tax Group and concentrate my practice on the following areas: the development of real estate with the low-income housing tax credit, the historic rehabilitation tax credit, the investment tax credit for renewable energy property, as well as the Illinois affordable housing tax credit; the taxation of partnerships and LLCs; and the taxation of not-for-profit organizations. I represent syndicators, developers, investors, lenders and nonprofit organizations in structuring tax-advantaged transactions.
I have also acted as an expert witness relating to tax credit transactions. I have represented clients in tax disputes before the IRS, the United States Tax Court and local tax authorities, with an emphasis on valuation issues.
Professional Affiliations
- American Bar Associations
- Member of Governing Committee of the American Bar Association Forum on Affordable Housing and Community Development Law, 2016-Present
- Co-Chair, Tax Credit and Equity Financing Committee of the Forum on Affordable Housing and Community Development Law, 2006-2016
- Moderator on several American Bar Association Teleconferences on legislation affecting low-income housing
- Regularly speaks on tax issues relating to Federal low-income housing and historic credits, and the Illinois affordable housing tax credit
Litigated Matters:
- Air Products and Chemicals, Inc. v. Alabama DOR, (No. S97-103)
- Norwest Corp. v. Comm’r, 108 TC 265 (1997)
- Nestle Holdings, Inc. v. Comm’r, T.C. Memo, 1995-441 (1995)
Publications
- Author, “Issues and Opportunities When Combining Opportunity Zones and LIHTC,” Novogradac Journal on Tax Credits (2019).
- Author, “Why Does My Tax Lawyer Keep Saying We Need Nonrecourse Debt for My Low-Income Housing Tax Credit Project,” 27 Journal of Affordable Housing and Community Development Law 435 (2018).
- Author, “Limited Time Offer-Bonus Depreciation Yield Enhancer”, Novogradac Journal on Tax Credits (2016).
- Author, “How to Save Your Property’s 9 Percent Rate (Even with 2014 Credits)”, Novogradac Journal on Tax Credits (2012).
- Author, “IRS Memo States TCAP Grants are Taxable at Time of TCAP Agreement is Signed”, Journal of Tax Credits, Vol II, Issue IV (2011).
- Contributing Author, “The Legal Guide to Affordable Housing Development”, 2nd Ed., American Bar Association (2011).
- Contributing Author, “Explanation and Analysis, American Recovery and Reinvestment Act of 2009”, Law and Analysis (2009).
- Co-Author, “Initiatives and Tools for the Preservation of Affordable Housing in Illinois”, 18 Journal of Affordable Housing and Community Development Law 403 (2009).
- Co-Author, “Low Income Housing Tax Credit Provisions of the Recovery Act of 2009: Tools to Close Financing Gaps in a Weak Tax Credit Equity Market”, 18 Journal of Affordable Housing and Community Development Law 463 (2009).
- Co-Author, “Attention Developers: Beware of TCAP Tax Pitfalls and Be Aware of Credit Exchange Tax Benefits”, Journal of Tax Credit Housing, Vol II, Issue IX (2009).
- Contributing Author, “Housing Assistance Act of 2008”, Law (2008).
- Contributing Author, Explanation and Analysis, Emergency Economic Stabilization Act of 2008″, Law (2008).
- Co-Author, “Impact of Housing and Economic Recovery Tax Act of 2008 on Current and Future Low-Income Housing Tax Credit Properties”, 18 Journal of Affordable Housing and Community Development Law 47 (2008).
- Co-Author with members of the American Bar Association Forum of many comment letters to the IRS and Treasury on matters related to tax credits and opportunity zones.
- Frequently quoted in Housing and Development Reporter and other tax credit publications.