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Stephen R. Looney

Shareholder
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Mr. Looney is the Chair of the firm’s Tax Department. He represents clients in a variety of business and tax matters including entity formation (S and C corporations, partnerships, and LLCs), acquisitions, dispositions, redemptions, liquidations, reorganizations, tax-free exchanges of real estate and tax controversies. His clients include closely held businesses, with an emphasis on medical and other professional practices. He is a former Chair of the S Corporations Committee of the American Bar Association’s Tax Section. He is Board Certified in Tax Law by the Florida Bar, as well as being a Certified Public Accountant (CPA).

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Professional and Civic Activities

  • American Bar Association
    • Tax Section
      • Member
      • Former Chair of the S Corporations Committee
  • The Florida Bar - Member
    • Health Law Section
    • Tax Section
  • American College of Tax Counsel - Fellow
  • Business Entities Journal
  • Board of Advisors and Department Heads, Current Developments Editor
  • The Florida Bar Foundation, Inc. – Fellow
  • Southern Federal Tax Institute - Board of Trustees
  • State Bar of Texas
  • The Missouri Bar
  • Missouri Society of Certified Public Accountants
  • Leadership Orlando, Graduate
  • Kiwanis Club of North Orlando - Member, Board of Directors and Past President
  • My Region, Regional Development Program - Member, Board of Directors

Education

  • Master of Laws (LL.M.) in Taxation: University of Florida Levin College of Law, Gainesville, Florida, 1985
    • Graduated First in Class
  • Juris Doctorate: University of Missouri Columbia School of Law, Columbia, Missouri, cum laude, 1984
    • Order of the Coif; Missouri Law Review, Member and Note and Comment Editor
  • Undergraduate Degree in Accounting and Business Administration: Drury  College, Springfield, Missouri, magna cum laude, 1981

Bar Admissions

  • Florida
  • Texas
  • Missouri
  • U.S. Tax Court

Recognition & Awards

  • Board Certified in Tax Law by The Florida Bar
  • Named an Outstanding Tax Attorney in Chambers USA, America’s Leading Business Lawyers, 2007 - 2011
  • Named an Outstanding Tax Attorney in The Best Lawyers in America®, 2006-2012
  • Named an Outstanding Tax, Business/Corporate and Health Care Attorney in Florida Super Lawyers Magazine, 2006- 2011
  • Named one of Orlando’s Best Tax Attorneys by Orlando Magazine, 2006-2012
  • Named an Outstanding Tax Attorney in Florida Trend Magazine’s Legal Elite, 2005 - 2006
  • Named an Outstanding Tax Attorney in Orlando Business Journal’s Best of the Bar, 2004
  • Listed in Marquis Who's Who in American Law
  • Martindale-Hubbell: AV Rating

Speaking Engagements

Classes and Seminars Taught

  • Deductibility of Losses Relating to Rental Activities, Orlando, Florida, March 19, 2012; May 21, 2012
  • Impact of the New Health Care Bills on Closely-Held Business, ABA Tax Section Meeting, San Diego, CA, February 17, 2012
  • Mergers & Acquisitions of S Corporations: How to Structure the Deal, ABA Live Video Webcast, December 13, 2011
  • "Current Issues Affecting S Corporations", University of Alabama’s 65th Federal Tax Clinic, Tuscaloosa, Alabama, November 18, 2011
  • “Current Issues Affecting S Corporations, Partnerships, LLCs and Disregarded Entities”, co-presented with Chris D'Amico, 2011 Florida Institute on Federal Taxation® Conference, sponsored by the Florida Institute of Certified Public Accountants, Orlando, Florida, November 11, 2011
  • "Mergers and Acquisitions of S Corporations", Florida Bar Tax Section Fall Meeting, Orlando, Florida, October 14, 2011
  • "Advising the Professional Service Firm", 46th Annual Southern Federal Tax Institute, Atlanta, Georgia, September 20, 2011
  • Compensation Issues Under Subchapters C, S & K, The University of Alabama 64th Annual Federal Tax Clinic, Tuscaloosa, AL, November 19, 2010
  • Current Issues Affecting S Corporations, Partnerships and LLCs, 2010 Florida Institute of Certified Public Accountants, Florida Institute on Federal Taxation® Conference, Orlando, FL, November 4, 2010
  • Operation of the Professional Corporation 2010:  Reasonable Compensation Issues for Professional and Other Service Businesses, New York University’s 69th Institute on Federal Taxation, New York, NY, October 18, 2010; San Diego, CA November 15, 2010
  • Federal Income Tax Update, Florida Institute of Certified Public Accountants 2010 University of Florida Accounting Conference, Gainesville, FL, October 15, 2010
  • Practice Governance Issues, Central Florida Medical Group Management Association (CFMGMA), Orlando, FL, August 11, 2010
  • Selected Federal Income Tax Developments Concerning S Corporations, Partnerships and C Corporations, Florida Institute of Certified Public Accountants, 2010 Florida Accounting and Business Expo, Tampa, FL, June 25, 2010
  • Impact of New Tax Rates on Choice of Entity Issues, ABA Teleconference and Live Audio Webcast, February 17, 2010
  • Impact of New Tax Rates on Choice of Entity Issues, panelist, ABA Tax Section S Corporations Committee 2010 Midyear Meeting, San Antonio, TX, January 22, 2010
  • Fundamentals of Taxation of S Corporations and Their Shareholders; Hot Topics in S Corporations, The Florida Bar 2010 Tax Practitioners Annual Review and Update, Orlando, January 19, 2010
  • S Corporation Hot Topics, 63rd Annual Federal Tax Clinic, University of Alabama, Tuscaloosa, AL, November 20, 2009
  • Hot Topics in S Corporations, 46th Annual Heart of America Tax Institute, Kansas City, MO, November 13, 2009
  • Reasonable Compensation and the Built-In Gains Tax, New York University’s 68th Institute on Federal Taxation, New York, NY, October 22, 2009; San Francisco, CA November 19, 2009
  • Hot Topics in S Corporations, Tax Section of The Florida Bar (hosted by DME and sponsored by Management Planning, Inc.), Orlando, FL, October 27, 2009
  • Due Diligence Issues for Acquisitions of S Corporations, 44th Annual Southern Federal Tax Institute, Atlanta, GA, October 20, 2009
  • Selected Recent Income Tax Developments Concerning S Corporations, Partnerships and C Corporations, Florida Institute of Certified Public Accountants 2009 University of Florida Accounting Conference, Gainesville, FL, October 16, 2009
  • Comments on Qualification of Debt as “Indebtedness of an S Corporation to a Shareholder” Under Section 1366(d)(1)(B) in Connection with Back-to-Back Loans, ABA Tax Section S Corporations Committee 2009 Fall Meeting, Chicago, IL, September 25, 2009
  • Hot Topics in S Corporations, 33rd Annual American Institute on Federal Taxation, Birmingham, AL, June 19, 2009
  • Hot Topics in S Corporations, University of North Carolina School of Law 2009 Tax Institute, Chapel Hill, NC, May 1, 2009
  • Fundamentals of Taxation of S Corporations and Their Shareholders; Hot Topics in S Corporations, The Florida Bar 2009 Tax Practitioners Annual Update, Tampa, FL, February 21, 2009
  • Open Account Indebtedness, ABA Tax Section S Corporations Committee 2009 Midyear Meeting, New Orleans, LA, January 9, 2009
  • S Corporation Hot Topics, 62nd Annual Federal Tax Clinic, University of Alabama, Tuscaloosa, AL, November 21, 2008
  • Using State Law Limited Liability Companies as S Corporations; S Corporation Hot Topics, Ft. Worth, TX, ACPEN Network Satellite Broadcast, November 19, 2008
  • Real Estate Dealer vs. Investor:  Maximizing Capital Gains, NYU 67th Institute on Federal Taxation, New York City, NY, October 22, 2008; San Diego, CA, November 12, 2008
  • The Best of Both Worlds:  Limited Liability Companies Taxed as S Corporations; Choice of Entity, Central Florida Estate Planning Council, Orlando, FL, September 25, 2008
  • Hot Topics in S Corporations, 43rd Annual Southern Federal Tax Institute, Atlanta, GA, September 23, 2008
  • Using State Law Limited Liability Companies as S Corporations, University of North Carolina School of Law 2008 Tax Institute, Chapel Hill, NC, April 25, 2008
  • Taxation of S Corporations and Their Shareholders, The Florida Bar Tax Practitioners Annual Update, Miami, FL, February 22, 2008
  • S Corporation Update, ABA Tax Section Closely Held Business Committee 2008 Midyear Meeting, Lake Las Vegas, NV, January 18, 2008
  • Limited Liability Companies Classified as S Corporations - Part II, ABA Tax Section S Corporations Committee 2008 Midyear Meeting, Lake Las Vegas, NV, January 18, 2008
  • Operating an S Corporation Through a State Law Limited Liability Company, The University of Texas School of Law 55th Annual Taxation Conference, Austin, TX, November 8, 2007
  • Selected Recent Income Tax Developments Concerning S Corporations, Partnerships, and C Corporations, Florida Institute of Certified Public Accountants, Gainesville, FL, November 1, 2007
  • Operating as an S Corporation Through a State Law Limited Liability Company, NYU 66th Institute on Federal Taxation, New York City, NY, October 24, 2007; San Francisco, CA, November 14, 2007
  • Obtaining Basis Increases for Loans to S Corporations:  Opportunities and Pitfalls in Structuring and Restructuring Loans to S Corporations, 59th Annual Virginia Conference on Federal Taxation, Charlottesville, VA, June 7, 2007
  • Limited Liability Companies Classified as S Corporations, ABA Tax Section S Corporations Committee 2007 May Meeting, Washington, DC, May 11, 2007
  • Taxation of S Corporations and Their Shareholders, The Florida Bar Tax Certification Review Course, Orlando, FL, February 23, 2007
  • The Uncertainty of Basis Increases in Connection with Back-to-Back Loans to S Corporations, ABA Tax Section S Corporations Committee 2007 Midyear Meeting, Hollywood, FL, January 19, 2007
  • So You Think It’s Easy to Obtain Basis Increases for Loans to S Corps? Think Again! Opportunities and Pitfalls in Structuring and Restructuring Loans To S Corporations, NYU 65th Institute on Federal Taxation, New York City, NY, October 25, 2006; San Diego, CA, November 15, 2006
  • Selected Recent Income Tax Developments, Florida Institute of Certified Public Accountants, Gainesville, FL, October 6, 2006
  • Redemptions and Purchases of S Corporation Stock, 30th Annual American Institute on Federal Taxation, Birmingham, AL, June 8, 2006
  • Redemptions and Purchases of S Corporation Stock, ABA Tax Section S Corporations Committee 2006 May Meeting, Washington, DC, May 6, 2006
  • Taxation of S Corporations and Their Shareholders, The Florida Bar - Tax Certification Review Course, Orlando, FL, February 24, 2006
  • Redemptions and Purchases of S Corporation Stock, ABA Tax Section S Corporations Committee 2006 Midyear Meeting, San Diego, CA, February 3, 2006
  • Redemptions and Purchases of S Corporation Stock, NYU 64th Institute on Federal Taxation, New York City, NY, October 26, 2005; San Francisco, November 16, 2005
  • Selected Recent Income Tax Developments, Florida Institute of Certified Public Accountants, Gainesville, FL, October 7, 2005
  • Taxation of S Corporations and Their Shareholders, 2005 Tax Certification Review Course, The Florida Bar, Orlando, FL, February 25, 2005
  • Converting a Personal Service Corporation, ABA Tax Section S Corporations Committee 2004 May Meeting, Washington, D.C., May 7, 2004
  • Reasonable Compensation Issues for Closely-Held and Service Companies, 2003 Mid-America Tax Conference, St. Louis, MO, November 18, 2003
  • Drafting Shareholder Agreements for Closely-Held Corporations, 54th Annual Tennessee Federal Tax Institute, Nashville, TN, September 25, 2003
  • Avoiding Unreasonable Compensation Attacks on Professional Service and Other Closely-Held Corporations, 54th Annual Tennessee Federal Tax Institute, Nashville, TN, September 25, 2003
  • Reasonable Compensation Issues for Closely-Held and Service Companies, ABA Teleconference and Live Audio Webcast, July 30, 2003
  • The Pediatric Surgical Associates Case and Reasonable Compensation for Closely-Held Businesses, 45th Annual Kentucky Institute on Federal Taxation, November 14, 2002
  • Reasonable Compensation Issues for Closely-Held and Service Companies, NYU 61st Institute on Federal Taxation, New York City, NY, October 23, 2002
  • S Corporation Modernization Act of 2001, ABA Tax Section S Corporations Committee 2002 Fall Meeting, Los Angeles, CA, October 18, 2002
  • The Pediatric Surgical Associates Case and Reasonable Compensation for Closely Held Businesses, 37th Annual Southern Federal Tax Institute, Atlanta, GA, September 24, 2002
  • Operation of the Service Corporation as an S Corporation Including Conversion of an Existing Service Corporation from C Status to S Status, ABA Tax Section S Corporations Committee Meeting, New Orleans, LA, 2002
  • Drafting S Corporation Shareholder Agreements, The Portland Tax Forum, Portland, OR, November 16, 2001
  • Drafting S Corporation Shareholder Agreements, The Attorney-CPA Tax Clinic, Seattle, WA, November 15, 2001
  • Drafting S Corporation Shareholder Agreements, NYU 60th Institute on Federal Taxation, San Francisco, CA, November 14, 2001
  • Drafting S Corporation Shareholder Agreements, 2001 Mid-America Tax Conference, St. Louis, MO, October 25, 2001
  • Drafting S Corporation Shareholder Agreements, NYU 60th Institute on Federal Taxation, New York City, NY, October 24, 2001
  • A Primer on the Built-In Gains Tax and Planning Opportunities, ABA Tax Section S Corporations Committee Meeting, Washington, DC, May 11, 2001
  • Drafting Shareholders’ Agreements, Including Special S Corporation Provisions, ABA Tax Section S Corporations Committee Meeting, Los Angeles, CA, October 13, 2000
  • The Proposed Section 1(h) Regulations-Treatment of Sale of S Corporation Stock, ABA Tax Section S Corporations Committee Meeting, San Diego, CA, January 21, 2000

Publications

Mr. Looney has written extensively on a variety of tax issues. His articles have appeared in a number of professional publications, including the Journal of TaxationThe Tax Lawyer, the Journal of S Corporation Taxation, the Journal of Partnership Taxation, the Journal of Corporate Taxation, and the Business Entities journal. A representative list of Mr. Looney’s articles are listed below.

  • Mr. Looney is a co-author of the two-volume treatise, "Tax Planning for S Corporations, Second Edition.", recently published by LexisNexis.  Tax Planning for S Corporations contains a comprehensive discussion of issues applicable to an S corporation from formation through sale, reorganization or liquidation.  The treatise takes a very practical approach and contains numerous examples and practice tips that apply to daily issues faced by tax accountants, tax attorneys and other tax professionals.  Mr. Looney co-authored the treatise with Mr. Richard B. Robinson and Mr. Ronald Levitt, LexisNexis, September, 2011
  • Current Developments Columns, Business Entities, 1999-present
  • Back-To-Back Loans and S Corporation Basis: Dazed and Confused, Journal of Passthrough Entities, May - June 2011
  • Due Diligence Issues Arising In Connection With The Acquisition of an S Corporation, co-authored with Ronald A. Levitt, Journal of Taxation, July 2011
  • ABA Section of Taxation Comments on Qualification of Debt as “Indebtedness of the S Corporation to the Shareholder,letter to the Commissioner of the Internal Revenue Service, July 26, 2010
  • Reasonable Compensation and the Built-In-Gains Tax, New York University 68th Institute on Federal Taxation, 2010
  • Letter to the Editor of Tax Notes Today, addressing flaws in the GAO’s Report on S Corporations, February 2010
  • Real Estate Dealer vs. Investor:  Maximizing Capital Gains, New York University 67th Institute on Federal Taxation, 2009
  • Operating as an S Corporation Through a State Law Limited Liability Company, New York University 66th Institute on Federal Taxation, 2008
  • So You Think It’s Easy to Obtain Basis Increases for Loans to S Corps?  Think Again!  Opportunities and Pitfalls in Structuring and Restructuring Loans to S Corporations, New York University 65th Institute on Federal Taxation, 2007
  • The Uncertainty of Basis Increases in Connection with Back-to-Back Loans to S Corporations, Business Entities, January/February, 2007
  • Redemptions and Purchases of S Corporation Stock, New York University 64th Institute on Federal Taxation, 2006
  • Avoiding Unreasonable Compensation Attacks on Professional Service and Other Closely Held Corporations, BNA’s Executive Compensation Library - Journal Reports: Law and Policy, January, 2004
  • Reasonable Compensation Issues for Closely-Held and Service Companies, New York University 61st Institute on Federal Taxation, 2003
  • Shareholder Agreements for Closely-Held Corporations, Business Entities, January/February, 2003
  • Internal Revenue Service Issues Proposed ESBT Regulations, Journal of Corporate Taxation, May/June, 2001
  • The Built-In Gains Tax Revisited: 15 Years Later, Business Entities, March/April, 2001
  • IRS Improves the Final QSub Regs. -- But Insists on Keeping the Step Transaction Doctrine, Journal of Taxation, Fall, 2000
  • Compensation Issues Under Subchapters C, S & K, The University of Alabama 64thAnnual Federal Tax Clinic, Tuscaloosa, AL, November 19, 2010
  • Current Issues Affecting S Corporations, Partnerships and LLCs, 2010 FloridaInstitute of Certified Public Accountants,Florida Institute on Federal Taxation®Conference, Orlando, FL, November 4, 2010
  • Operation of the Professional Corporation 2010:Reasonable Compensation Issues for Professional and Other Service Businesses, New York University’s 69th Institute on Federal Taxation, New York, NY, October 18, 2010; San Diego, CA November 15, 2010
  • Federal Income Tax Update, Florida Institute of Certified Public Accountants 2010 University of Florida Accounting Conference, Gainesville, FL, October 15, 2010
  • Practice Governance Issues, Central Florida Medical Group Management Association (CFMGMA), Orlando, FL, August 11, 2010
  • Selected Federal Income Tax Developments Concerning S Corporations, Partnerships and C Corporations, Florida Institute of Certified Public Accountants, 2010 Florida Accounting and Business Expo, Tampa, FL, June 25, 2010
  • Impact of New Tax Rates on Choice of Entity Issues, ABA Teleconference and Live Audio Webcast, February 17, 2010
  • Impact of New Tax Rates on Choice of Entity Issues, panelist, ABA Tax Section S Corporations Committee 2010 Midyear Meeting, San Antonio, TX, January 22, 2010
  • Fundamentals of Taxation of S Corporations and Their Shareholders; Hot Topics in S Corporations, The Florida Bar 2010 Tax Practitioners Annual Review and Update, Orlando, January 19, 2010
  • S Corporation Hot Topics, 63rd Annual Federal Tax Clinic, University of Alabama, Tuscaloosa, AL, November 20, 2009
  • Hot Topics in S Corporations, 46th Annual Heart of America Tax Institute, Kansas City, MO, November 13, 2009
  • Reasonable Compensation and the Built-In Gains Tax, New York University’s 68th Institute on Federal Taxation, New York, NY, October 22, 2009; San Francisco, CA November 19, 2009
  • Hot Topics in S Corporations, Tax Section of The Florida Bar (hosted by DME and sponsored by Management Planning, Inc.), Orlando, FL, October 27, 2009
  • Due Diligence Issues for Acquisitions of S Corporations, 44th Annual Southern Federal Tax Institute, Atlanta, GA, October 20, 2009
  • Selected Recent Income Tax Developments Concerning S Corporations, Partnerships and C Corporations, Florida Institute of Certified Public Accountants 2009 University of Florida Accounting Conference, Gainesville, FL, October 16, 2009
  • Comments on Qualification of Debt as “Indebtedness of an S Corporation to a Shareholder” Under Section 1366(d)(1)(B) in Connection with Back-to-Back Loans, ABA Tax Section S Corporations Committee 2009 Fall Meeting, Chicago, IL, September 25, 2009
  • Hot Topics in S Corporations, 33rd Annual American Institute on Federal Taxation, Birmingham, AL, June 19, 2009
  • Hot Topics in S Corporations, University of North Carolina School of Law 2009 Tax Institute, Chapel Hill, NC, May 1, 2009
  • Fundamentals of Taxation of S Corporations and Their Shareholders; Hot Topics in S Corporations, The Florida Bar 2009 Tax Practitioners Annual Update, Tampa, FL, February 21, 2009
  • Open Account Indebtedness, ABA Tax Section S Corporations Committee 2009 Midyear Meeting, New Orleans, LA, January 9, 2009
  • S Corporation Hot Topics, 62nd Annual Federal Tax Clinic, University of Alabama, Tuscaloosa, AL, November 21, 2008
  • Using State Law Limited Liability Companies as S Corporations; S Corporation Hot Topics, Ft. Worth, TX, ACPEN Network Satellite Broadcast, November 19, 2008
  • Real Estate Dealer vs. Investor:Maximizing Capital Gains, NYU 67th Institute on Federal Taxation, New York City, NY, October 22, 2008; San Diego, CA, November 12, 2008
  • The Best of Both Worlds:Limited Liability Companies Taxed as S Corporations; Choice of Entity, Central Florida Estate Planning Council, Orlando, FL, September 25, 2008
  • Hot Topics in S Corporations, 43rd Annual Southern Federal Tax Institute, Atlanta, GA, September 23, 2008
  • Using State Law Limited Liability Companies as S Corporations, University of North Carolina School of Law 2008 Tax Institute, Chapel Hill, NC, April 25, 2008
  • Taxation of S Corporations and Their Shareholders, The Florida Bar Tax Practitioners Annual Update, Miami, FL, February 22, 2008
  • S Corporation Update, ABA Tax Section Closely Held Business Committee 2008 Midyear Meeting, Lake Las Vegas, NV, January 18, 2008
  • Limited Liability Companies Classified as S Corporations - Part II, ABA Tax Section S Corporations Committee 2008 Midyear Meeting, Lake Las Vegas, NV, January 18, 2008
  • Operating an S Corporation Through a State Law Limited Liability Company, The University of Texas School of Law 55th Annual Taxation Conference, Austin, TX, November 8, 2007
  • Selected Recent Income Tax Developments Concerning S Corporations, Partnerships, and C Corporations, Florida Institute of Certified Public Accountants, Gainesville, FL, November 1, 2007
  • Operating as an S Corporation Through a State Law Limited Liability Company, NYU 66th Institute on Federal Taxation, New York City, NY, October 24, 2007; San Francisco, CA, November 14, 2007
  • Obtaining Basis Increases for Loans to S Corporations:Opportunities and Pitfalls in Structuring and Restructuring Loans to S Corporations, 59th Annual Virginia Conference on Federal Taxation, Charlottesville, VA, June 7, 2007
  • Limited Liability Companies Classified as S Corporations, ABA Tax Section S Corporations Committee 2007 May Meeting, Washington, DC, May 11, 2007
  • Taxation of S Corporations and Their Shareholders, The Florida Bar Tax Certification Review Course, Orlando, FL, February 23, 2007
  • The Uncertainty of Basis Increases in Connection with Back-to-Back Loans to S Corporations, ABA Tax Section S Corporations Committee 2007 Midyear Meeting, Hollywood, FL, January 19, 2007
  • SoYou Think It’s Easy to Obtain Basis Increases for Loans to S Corps? Think Again! Opportunities and Pitfalls in Structuring and Restructuring Loans To S Corporations, NYU 65th Institute on Federal Taxation, New York City, NY, October 25, 2006; San Diego, CA, November 15, 2006
  • Selected Recent Income Tax Developments, Florida Institute of Certified Public Accountants, Gainesville, FL, October 6, 2006
  • Redemptions and Purchases of S Corporation Stock, 30th Annual American Institute on Federal Taxation, Birmingham, AL, June 8, 2006
  • Redemptions and Purchases of S Corporation Stock, ABA Tax Section S Corporations Committee 2006 May Meeting, Washington, DC, May 6, 2006
  • Taxation of S Corporations and Their Shareholders, The Florida Bar - Tax Certification Review Course, Orlando, FL, February 24, 2006
  • Redemptions and Purchases of S Corporation Stock, ABA Tax Section S Corporations Committee 2006 Midyear Meeting, San Diego, CA, February 3, 2006
  • Redemptions and Purchases of S Corporation Stock, NYU 64th Institute on Federal Taxation, New York City, NY, October 26, 2005; San Francisco, November 16, 2005
  • Selected Recent Income Tax Developments, Florida Institute of Certified Public Accountants, Gainesville, FL, October 7, 2005
  • Taxation of S Corporations and Their Shareholders, 2005 Tax Certification Review Course, The Florida Bar, Orlando, FL, February 25, 2005
  • Converting a Personal Service Corporation, ABA Tax Section S Corporations Committee 2004 May Meeting, Washington, D.C., May 7, 2004
  • Reasonable Compensation Issues for Closely-Held and Service Companies, 2003 Mid-America Tax Conference, St. Louis, MO, November 18, 2003
  • Drafting Shareholder Agreements for Closely-Held Corporations, 54th Annual Tennessee Federal Tax Institute, Nashville, TN, September 25, 2003
  • Avoiding Unreasonable Compensation Attacks on Professional Service and Other Closely-Held Corporations, 54th Annual Tennessee Federal Tax Institute, Nashville, TN, September 25, 2003
  • Reasonable Compensation Issues for Closely-Held and Service Companies, ABA Teleconference and Live Audio Webcast, July 30, 2003
  • The Pediatric Surgical Associates Case and Reasonable Compensation for Closely-Held Businesses, 45th Annual Kentucky Institute on Federal Taxation, November 14, 2002
  • Reasonable Compensation Issues for Closely-Held and Service Companies, NYU 61st Institute on Federal Taxation, New York City, NY, October 23, 2002
  • S Corporation Modernization Act of 2001, ABA Tax Section S Corporations Committee 2002 Fall Meeting, Los Angeles, CA, October 18, 2002
  • The Pediatric Surgical Associates Case and Reasonable Compensation for Closely Held Businesses, 37th Annual Southern Federal Tax Institute, Atlanta, GA, September 24, 2002
  • Operation of the Service Corporation as an S Corporation Including Conversion of an Existing Service Corporation from C Status to S Status, ABA Tax Section S Corporations Committee Meeting, New Orleans, LA, 2002
  • Drafting S Corporation Shareholder Agreements, The Portland Tax Forum, Portland, OR, November 16, 2001
  • Drafting S Corporation Shareholder Agreements, The Attorney-CPA Tax Clinic, Seattle, WA, November 15, 2001
  • Drafting S Corporation Shareholder Agreements, NYU 60th Institute on Federal Taxation, San Francisco, CA, November 14, 2001
  • Drafting S Corporation Shareholder Agreements, 2001 Mid-America Tax Conference, St. Louis, MO, October 25, 2001
  • Drafting S Corporation Shareholder Agreements, NYU 60th Institute on Federal Taxation, New York City, NY, October 24, 2001
  • A Primer on the Built-In Gains Tax and Planning Opportunities, ABA Tax Section S Corporations Committee Meeting, Washington, DC, May 11, 2001
  • Drafting Shareholders’ Agreements, Including Special S Corporation Provisions, ABA Tax Section S Corporations Committee Meeting, Los Angeles, CA, October 13, 2000
  • The Proposed Section 1(h) Regulations-Treatment of Sale of S Corporation Stock, ABA Tax Section S Corporations Committee Meeting, San Diego, CA, January 21, 2000