The New Tax Return Preparer Rules (Circular 230)

Trevor Ackerman is a Senior Manager in KPMG’s Tax Controversy Services (“TCS”) practice in Philadelphia, Pennsylvania. Trevor has extensive experience in IRS administrative practice before the Examination and Appeals Divisions, as well as in Tax Court litigation. His practice also extends to IRS dispute resolution procedures, including: Fast Track, Technical Advice Memorandum (“TAM”) procedures, Pre-Filing Agreements, the Compliance Assurance Program (“CAP”), and the Advance Pricing Agreement (“APA”) Program. His substantive experience includes a wide-range of complex corporate tax issues.

Prior to joining KPMG, Trevor was a Senior Attorney with the IRS Office of Chief Counsel, Large and Mid-Size Business Division (LMSB), where he was legal advisor to the Examination and Appeals Divisions. He also represented the IRS before the United States Tax Court on numerous occasions.

While with the IRS Office of Chief Counsel, Trevor served as Industry Counsel for Domestic Production, where he was the principal field attorney on the section 199 published guidance projects from the inception of the American Jobs Creation Act of 2004. During his tenure with the IRS, Trevor briefed the IRS Commissioner and senior IRS and Treasury officials. He also was a leader on the team that designed and implemented the section 199 Examination.

Trevor served as a member of the International Field Counsel Cadre, advising the IRS on inbound and outbound international taxation matters, including issues in transfer pricing, foreign tax credits, permanent establishment and tax treaty interpretation. He also has extensive experience with tax issues that affect insurance companies. While with the IRS, Trevor served on the litigation team in Capital Blue Cross v. Commissioner, 122 T.C. 224 (2004) (whether Blue Cross Blue Shield taxpayer is entitled to a loss upon the termination of health insurance contracts based on the fair market value of those contracts in 1987).

Before joining the IRS, Trevor worked at another Big Four accounting firm, where he provided transfer pricing and state tax consulting services to large corporations in a variety of industries.

Trevor received a dual degree from the University of Pennsylvania’s Wharton School of Business and College of Arts & Sciences. He earned his J.D. from the Villanova University School of Law. Trevor is a member of the Bars of Pennsylvania and New Jersey, and he is admitted to practice before the United States Tax Court. Trevor is also a Certified Public Accountant, and he is a member of the American Institute of Certified Public Accountants. Trevor is a frequent lecturer on IRS practice and procedure, section 199, income and tax accounting issues, and transfer pricing applications.

Trevor can be reached at (267) 256-1873 or atackerman@kpmg.com.

In tax controversy, Mr. Walton works with clients at all stages of tax controversies from the audit level to IRS Appeals to litigation in the Tax Court and other federal courts. In docketed Tax Court cases, Mr. Walton represents or has represented Compaq Computer Corporation (T.C. Doc. No. 24238-96), St. Jude Medical, Inc. (T.C. Doc. Nos. 13533-97 and 13534-97), and Seagate Technology, Inc. (T.C. Doc. No. 15086-98), and Software Finance and Tax Executives Council (SoFTEC) as amicus curiae in Xilinx, Inc. (T.C. Doc. No. 4142-01). Additionally, Mr. Walton represented Compaq Computer Corporation in its appeal to the Fifth Circuit U.S. Court of Appeals (5th Cir. Dkt. No. 00-60648) and represented Aeroquip-Vickers, Inc. (f/k/a Trinova Corp.) in the government’s appeal to the Sixth Circuit U.S. Court of Appeals (6th Cir. Dkt. No. 01-2741) rev’d. In tax planning, Mr. Walton has experience with international tax planning, including mergers and acquisitions, tax deferral, and withholding taxes. In addition, Mr. Walton has worked with tax issues arising with a variety of financial products.

Education & Bar Admittance Mr. Walton is a graduate of Harvard Law School (J.D., 1996). In addition, he graduated from the University of Illinois with a B.S. in Accountancy in 1993. He also received an Elijah Watt Sells Certificate for passing the Certified Public Accountant examination with High Distinction. He was admitted to practice in Illinois in 1996 and is a member of the bar of the U.S. Tax Court, the United States Courts of Appeals for the Fifth, Sixth, and Eighth Circuits, the Court of Federal Claims, and the United States District Court for the Northern District of Illinois, and the United States Supreme Court.

Mr. Walton is a member of Baker & McKenzie LLP's Best Practices Committee.

Joel is a partner in the law firm of Meadows, Collier, Reed, Cousins & Blau, L.L.P. in Dallas, Texas. His practice focuses on taxation and litigation of controversies arising under the Internal Revenue Code. He represents individuals and companies in audits, administrative appeals and collection matters. When a matter cannot be resolved administratively he represents clients in United States Tax Court, Federal District Courts and the United States Court of Federal Claims. In addition to civil tax matters, Joel is frequently called upon to represent individuals and corporations in white collar criminal matters. He has experience in representing individuals and companies in tax fraud, bankruptcy fraud, bank fraud and environmental matters. Joel is a member of the State Bar of Texas and the American Bar Association and an active member of the Tax and Criminal Law sections of these organizations. He is also a member of the Dallas Bar Association and the Collin County Bar Association. Joel is an active speaker on substantive and procedural tax issues for attorneys, CPAs, and other professional groups and is Board Certified in Tax by the Texas Board of Legal Specialization. He has been named a Texas Super Lawyer for the past five years (2003-2008) by Texas Monthly and Law & Politics Magazine. Joel co-authored an article in the May/June 2006 issue of The Value Examiner (National Association of Certified Valuation Analysts publication) titled, "6 Keys to Avoiding Section 6701 Penalties." He attended Southern Methodist University (B.A., 1985) and the University of Texas School of Law (J.D., 1988) and was admitted to practice law in Texas in 1988. Joel resides in Plano, Texas with his wife, Tammy and their three children, Mitchell, Katie and Claire.
E-mail: jcrouch@meadowscollier.com