• Argued six cases before the United States Court of Appeals for the Second, Third, Eleventh, and D.C. Circuits on a range of cases including Federal Trade Commission Act, civil taxation, direct criminal appeals, and habeas corpus.
• Successfully tried a Tax Court case (Meggs v. Comm’r, T.C. Memo. 2019-5) regarding the treatment of the transfer of intellectual property.
• Successfully tried a Tax Court case (Rademacher v. Comm’r, T.C. Memo. 2018-43) regarding deductibility of employee business expense deductions, charitable contributions, and accuracy-related penalties.
• Expert defense witness in federal criminal tax trial regarding the preparation of false income tax returns.
• Represented a taxpayer before the Canadian Revenue Authority and the Internal Revenue Service regarding request for competent authority relief from double taxation under the United States-Canada tax treaty.
• Expert witness in a civil malpractice action regarding criminal defense counsel’s failure to move to dismiss based on a speedy trial violation.
• Representing an individual in various Marjorie Stoneman Douglas (Parkland, Florida) school shooting cases.
• Counsel for the Plaintiff in a class-action case against the Government of the Virgin Islands regarding the Government of the Virgin Islands refusal to pay income tax returns within the time period required by the Internal Revenue Code.

• Argued before the United States Courts of Appeals for the 1st, 2nd, 3rd, 4th, 8th, 9th, and 11th Circuits on a range of cases such as tax, bank secrecy act, securities fraud, intervention, and bankruptcy fraud; argued five cases before the Virgin Islands Supreme Court on a range of cases including preliminary injunction, direct criminal appeals, and habeas corpus.
• Represented, as lead counsel, the New York City Detectives, Lieutenants, and Captains police unions in connection with the “stop and frisk” litigation (Floyd v. City of New York) in the Second Circuit.
• Successfully represented a taxpayer against the U.S. Department of Justice in an appeal of summary judgment entered in favor of the Government (United States v. Hom) involving a case of first impression addressing the applicability of the Bank Secrecy Act/Foreign Bank Account Report (“FBAR”) to on-line poker websites before the Ninth Circuit.
• Lead counsel on numerous cases before the U.S. Tax Court, the U.S. District Courts, and the U.S. Court of Federal Claims on a range of cases including tax, IRS summons enforcement, and civil investigative demands; tried seven cases before the U.S. Tax Court.
• Represented a client in federal case involving Title III wiretaps, administrative subpoenas, and a warrantless search of cellular telephone.
• Obtained a full trial acquittal in a federal criminal case (United States v. Williams, case no. 3:10-cr-39 (D.V.I.)).
• Represented targets of grand jury investigations before the U.S. District Court for the Southern District of Florida in petitions to quash grand jury subpoenas.
• Obtained Florida Bar Board Certification as a Specialist in Criminal Appellate Law.

• Acted as lead counsel on numerous U.S. Tax Court cases, and four District Court of the Virgin Islands tax cases, involving alleged Virgin Islands tax shelters and residency disputes. Lead counsel on thirteen District Court cases involving summons enforcement issued to third-parties regarding Virgin Islands taxpayer audits.
• Acted as lead counsel on two U.S. District Court freedom of information act (FOIA) cases for Virgin Islands taxpayers.
• Tried a District Court civil tax case involving disputed Virgin Islands residency.
• Acted as lead counsel on five U.S. Court of Appeals cases involving direct criminal and collateral attack appeals.
• Was responsible for all stages of tax litigation including responding to information document requests, interviewing and preparing witnesses for examination, representing clients in IRS interviews, and drafting protests to IRS 30 day letters.
• Drafted tax opinions regarding tax consequences of the interplay of the Internal Revenue Code as mirrored to the Virgin Islands for issues of source and effectively connected income, for both inbound and outbound transactions.
• Represented a client in a federal international criminal case involving mutual legal assistance treaties (MLATs), and taking of foreign evidence via letters rogatory and Fed. R. Crim. P. 15 depositions.

• Drafted tax opinions analyzing U.S. tax consequences of a multinational corporation’s global restructuring involving domestic entities and controlled foreign corporations. Performed tax research and drafted internal memoranda for corporate mergers and acquisitions.
• Reviewed SEC filings and assessed tax attributes of potential targets for clients’ tax due diligence.
• Assisted in the tax calculations under GAAP for quarterly and annual SEC filings and for financial statement “carve outs” for corporate spin-offs.
• Member of a tax team that audited a regulated corporation’s tax calculations and uncertain tax positions.
• Produced pro forma and consolidated federal returns for domestic corporations and informational returns for controlled foreign corporations and foreign disregarded entities.

• Was awarded Attorney of the year 2003, County Division; held office trial record.
• Conducted all aspects of case investigation and discovery, including potential witness interviews, client direct and cross examination preparation, and deposing scores of prosecution witnesses.
• Handled every stage of case litigation including drafting and arguing dispositive motions, jury trials, and appeals.

• Panelist, “Ensuring Ethical Client Solicitations,” American Bar Association – Tax Section, 2015 May Meeting
• Presenter, “Accounting for Bitcoin,” Florida Institute of Certified Public Accountants, 30th Annual Accounting Show, September 2015
• Panelist, “Civil and Criminal Enforcement Tools for Use Against Overseas Taxpayers and Taxpayers with Overseas Assets,” American Bar Association – Tax Section, 2016 October Meeting
• Panelist, “How to Affirmatively Defend an FBAR (“Foreign Bank Account Report”) Case,” American Bar Association – Tax Section, 2017 January Meeting
• Presenter, “CPAs Civil & Criminal Liability in Tax Practice,” Florida Institute of Certified Public Accountants, 2018 Accounting & Business Show, September 2018

• U.S. Supreme Court
• 1st, 2nd, 3rd, 4th, 8th, 9th,11th, Federal, and D.C. Circuits
• U.S. Tax Court
• U.S. Court of Federal Claims
• U.S. Court of International Trade
• United States District Courts for the Southern District of Florida, Middle District of Florida, District of the Virgin Islands, District of New Jersey, Southern District of New York, Western District of Michigan, D.C. District, Northern District of Illinois, and the District of Colorado.

United States Courts of Appeals

• McLane v. Comm’r of Internal Revenue, 24 F.4th 316 (4th Cir. 2022)
• Morton v. United States Virgin Islands, 128 A.F.T.R.2d 2021-7051 (3d Cir. Dec. 2021)
• United States v. Brooks, 841 F. App’x 346 (3d Cir. 2020), cert. denied, 141 S. Ct. 2654 (2021)
• United States v. Baxter, 951 F.3d 128 (3d Cir. 2020), cert. denied, 141 S. Ct. 1269 (2021)
• In re Brooks, 791 F. App'x 327 (3d Cir. 2020)
• Paez v. Sec'y, Fla. Dep't of Corr., 947 F.3d 649 (11th Cir.), cert. denied sub nom. Gus Paez v. Inch, 141 S. Ct. 309 (2020)
• Simon v. Gov’t of the Virgin Islands, 929 F.3d 118 (3d Cir. 2019)
• Myers v. Comm’r of Internal Revenue Serv., 928 F.3d 1025 (D.C. Cir. 2019)
• United States v. James, 928 F.3d 247 (3d Cir. 2019)
• Fed. Trade Comm'n v. Rensin, 771 F. App'x 84 (2d Cir. 2019)
• Jones v. Sec’y, Dep’t of Corr., 778 F. App’x 626 (11th Cir. 2019)
• United States v. Castillo, 772 F. App’x 11 (3d Cir. 2019)
• United States v. Ayala, 917 F.3d 752 (3d Cir. 2019)
• Martinez v. Warden Golden Grove Corr. Facility, 757 F. App’x 86 (3d Cir. 2018)
• Crim v. Comm’r of Internal Revenue, 742 F. App’x 309 (9th Cir. 2018)
• Thompson v. Comm’r of Internal Revenue, 742 F. App’x 316 (9th Cir. 2018)
• United States v. Castillo, 742 F. App’x 610 (3d Cir. 2018), cert. denied, 2019 WL 660008 (Feb. 19, 2019)
• Berkun v. Comm’r of Internal Revenue, 890 F.3d 1260 (11th Cir. 2018)
• Teffeau v. Comm’r of Internal Revenue, 709 F. App’x 170 (4th Cir. 2017)
• United States v. Brooks, 872 F.3d 78 (2d Cir. 2017), cert. denied, 139 S. Ct. 171 (2018)
• Gillette v. Prosper, 858 F.3d 833 (3d Cir. 2017)
• Fed. Trade Comm’n v. Rensin, 687 F. App’x 3 (2d Cir. 2017)
• United States v. Fredericks, 684 F. App’x 149 (3d Cir. 2017)
• United States v. Willis, 844 F.3d 155 (3d Cir. 2016)
• United States v. Crim, 665 Fed. App’x 144 (3d Cir. 2016)
• United States v. Hom, 657 Fed. App’x 652 (9th Cir. 2016)
• United States v. Macias, 654 Fed. App’x 458 (11th Cir. 2016)
• Gov’t of the Virgin Islands v. Mills, 821 F.3d 488 (3d Cir. 2016)
• Gangi v. United States, 638 Fed. App’x 16 (1st Cir. 2016)
• United States v. Moore, 628 Fed. App’x 736 (11th Cir. 2016)
• United States v. Gibson, 615 Fed. App’x 619 (11th Cir. 2015)
• Fisher v. Sec’y, Florida Dep’t of Corr., 616 Fed. App’x 916 (11th Cir. 2015)
• In re Martinez, 594 Fed. App’x 96 (3d Cir. 2015)
• Stoddard v. Sec’y, Florida Dep’t of Corr., 600 Fed. App’x 696 (11th Cir. 2015)
• Patterson v. U.S. Virgin Islands, 597 Fed. App’x 671 (3d Cir. 2015)
• Floyd v. City of New York, 770 F.3d 1051 (2d Cir. 2014)
• Winthrop-Redin v. United States, 767 F.3d 1210 (11th Cir. 2014)
• Hill v. Sec’y, Florida Dep't of Corr., 578 Fed. App’x 805 (11th Cir. 2014)
• Marcum LLP v. United States, 753 F.3d 1380 (Fed. Cir. 2014)
• United States v. Locklear, 575 Fed. App’x 125 (4th Cir. 2014)
• United States v. Curshen, 567 Fed. App’x 815 (11th Cir. 2014)
• United States v. Territory of Virgin Islands, 748 F.3d 514 (3d Cir. 2014)
• Gillette v. Territory of Virgin Islands, 563 Fed. App’x 191 (3d Cir. 2014)
• United States v. Dames, 556 Fed. App’x 793 (11th Cir. 2014)
• United States v. Crim, 553 Fed. App’x 170 (3d Cir. 2014) cert. denied, 134 S. Ct. 2851 (2014)
• United States v. Gillette, 738 F.3d 63 (3d Cir. 2013) cert. denied, 134 S. Ct. 2714 (2014)
• United States v. Benoit, 730 F.3d 280 (3d Cir. 2013)
• United States v. Curbelo, 726 F.3d 1260 (11th Cir. 2013) cert. denied, 134 S. Ct. 962 (2014)
• United States v. Schuerer, 525 Fed. App’x 902 (11th Cir. 2013) cert. denied, 134 S. Ct. 1350 (2014)
• Cooper v. Comm’r, 718 F.3d 216 (3d Cir. 2013)
• Apex Oil Co. v. Comm’r, 500 Fed. App’x. 552 (8th Cir. 2013)
• Simon v. Gov’t of the Virgin Islands, 679 F.3d 109 (3d Cir. 2012)
• McHenry v. Comm’r, 677 F.3d 214 (4th Cir. 2012)
• Birdman v. Office of the Governor, 677 F.3d 167 (3d Cir. 2012)
• Cross v. Comm’r, 499 Fed. App’x 857 (11th Cir. 2012)
• In re Morton, 491 Fed. App’x 291 (3d Cir. 2012)
• United States v. Russell, 479 Fed. App’x 420 (3d Cir. 2012)
• Gangi v. United States, 453 Fed. App’x 255 (3d Cir. 2011)
• United States v. Crim, 451 Fed. App’x 196 (3d Cir. 2011) cert. denied, 132 S. Ct. 2682 (2012)
• Cherys v. United States, 405 Fed. App’x 589 (3d Cir. 2011)
• Lizardo v. United States, 619 F.3d 273 (3d Cir. 2010)

District Courts, Tax Court, & Court of Federal Claims

• Meggs v. Comm’r of Internal Revenue, T.C. Memo. 2019-5 (Tax Court 2019)
• Rademacher v. Comm’r of Internal Revenue, T.C. Memo. 2018-43 (Tax Court 2018)
• Mencias v. Comm’r of Internal Revenue, T.C. Memo. 2017-109 (Tax Court 2017)
• Taft v. Comm’r of Internal Revenue, T.C. Memo. 2017-66 (Tax Court 2017)
• Thompson v. Comm’r of Internal Revenue, 148 T.C. 59 (Tax Court 2017)
• Battat v. Comm’r of Internal Revenue, 148 T.C. 32 (Tax Court 2017)
• Nutrition Formulators, Inc. v. Comm’r, T.C. Memo 2016-60 (Tax Court 2016)
• Simon v. Gov’t of the Virgin Islands, 116 F.Supp.3d 529 (D.V.I. 2015)
• Cooper v. Comm’r, T.C. Memo. 2015-72 (Tax Court 2015)
• Uribe v. Comm’r, T.C. Memo. 2014-116 (Tax Court 2014)
• Gangi v. United States, 2 F.Supp.3d 12 (D. Mass. 2014)
• Sugarloaf Fund LLC v. Comm’r, 141 T.C. No. 4 (Tax Court 2013)
• Marcum LLP v. United States, 112 Fed. Cl. 167 (Fed. Cl. 2013)
• Villareale v. Comm’r, T.C. Memo 2013-74 (Tax Court 2013)
• Huff v. Comm’r, 138 T.C. 258 (Tax Court 2012)
• Cross v. Comm’r, T.C. Memo 2012-344 (Tax Court 2012)
• Philemond v. Comm’r, T.C. Memo 2012-29 (Tax Court 2012)
• Gaitan v. Comm’r, T.C. Memo. 2012-3 (Tax Court 2012)
• Huff v. Comm’r, 135 T.C. 605 (Tax Court 2010)
• Huff v. Comm’r, 135 T.C. 222 (Tax Court 2010
• Vento v. IRS, 714 F. Supp.2d 137 (D.D.C. 2010)
• Twin Palms Resort, LLC v. United States, 676 F. Supp.2d 1350 (S.D. Fla. 2009)

Virgin Islands Supreme Court

• Simon v. Gov’t of Virgin Islands, 67 V.I. 702 (V.I. 2017)
• In re: Gillette, 64 V.I. 440 (V.I. 2016)
• Yusuf v. Hamed, 59 V.I. 841 (V.I. 2013)
• Farrington v. People, 59 V.I. 690 (V.I. 2013)
• Merrifield v. People, 56 V.I. 769 (V.I. 2012))
• In re Morton, 56 V.I. 313 (V.I. 2012)
• Farrington v. People, 55 V.I. 644 (V.I. 2012)