The focus of Jack’s Practice is Federal income tax controversy matters, including specifically IRS audits and appeals and litigation in all federal courts. He has litigated in the U.S. Tax Court, U.S. District Court(including Bankruptcy Courts), U.S. Court of Federal Claims, most of the U.S. Courts of Appeal, and United States Supreme Court, involving the spectrum of tax issues (e.g., transfer pricing (§ 482)), including both civil and criminal representation in § 482 issues and Competent Authority representation, oil and gas taxation; exempt organization taxation, accounting issues, constructive sales prices for the manufacturer’s excise tax (§ 482-type analysis), foreign tax credit and outbound transfer issues, business purchase issues (including valuation and depreciation or amortization of tangible and intangible assets), Trust Fund Recovery Penalty matters and a range of other civil and criminal tax disputes. He has represented clients before the IRS in audits, appeals, assessments, collections and criminal investigations; he has also represented clients before the Justice Department Tax Division Criminal Enforcement Section and U.S. Attorney’s office in criminal matters.
Jack represented one of the defendants in the gorilla of all tax criminal cases in the known, or at least knowable, universe — the KPMG individual defendant criminal case, United States v. Stein (S.D. N.Y. – S1 05 Crim. 0888 (LAK)), which generated many published opinions, including leading opinions in tax and white collar criminal defense dismissing the indictment against 13 defendants because the federal prosecutors had behaved unconstitutionally in forcing KPMG to withdraw payment of attorneys fees. See e.g. United States v. Stein, 435 F. Supp. 2d 330 (S.D.N.Y. 2006) and United States v. Stein, 495 F. Supp. 2d 390 (S.D.N.Y. 2007), aff’d United States v. Stein, 541 F.3d 130 (2d Cir. 2008); and the Wikipedia entry here.
- U. S. Department of Justice, Tax Division Trial Section 1974-1977
- U.S. Department of Justice Appellate Section 1969-1974
- University of Houston-Adjunct Professor of Law in the Tax Program, 1982-1988 and 1993-2005 (taught Tax Procedure (each Fall Semester) and Tax Fraud and Money Laundering (every other Spring Semester)).
- Participant and Panelist for programs by the ABA Tax Section’s Court Procedure Committee; Tax Executives Institute, the Texas State Bar (partnerships and oil and gas), Houston Bar Association (partnerships), South Carolina State Bar (partnerships), New York University Federal Tax Institute (tax procedure); University of Houston School of Law (Criminal Tax Symposium in 2008; earlier real estate taxation and partnerships), and Southern Methodist University School of Law (partnerships and oil and gas taxation).
Author of Books and Articles (see the listing of recent publications here)
- Member American Bar Association, Tax Section. Past Subcommittee Chair and currently active in the Court Procedure Committee on certain large case matters.
- State Bar of Texas, Tax Section.
- Admitted to Bars of Texas (1977) and numerous courts, including the Southern District of Texas, the Fifth Circuit and the Supreme Court.
- University of South Carolina, A.B., 1964.
- University of Virginia, LL.B., 1967.
- New York University LL.M. (Taxation), 1969.
- Honors Special Commendation Award at Attorney General’s Awards Ceremony at the Justice Department; Justice Department Tax Division Meritorious Service Award.
- Listed since 1997 among Houston’s top tax lawyers in The Best Lawyers in America, the premier national peer group lawyer ratings.
- Listed in 2 of 3 Texas Lawyer’s Quintennial “Go-to” Guide (Oct. 2002 and December 2012) as being among Texas’ top 5 top tax lawyers.
- Listed in Chambers USA Guide to America’s Leading Lawyers for Business.
- Board Certified – Tax Law, Texas Board of Legal Specialization.
Download Resume in pdf format here.