Tax Litigator, Jeff Erney, joins Dentons in Washington

Current tax litigation

• Hyacinth Lofts, LTD v. Commissioner: Lead counsel for a partnership challenging the disallowance of charitable contribution of historic conservation easement, and related additions to tax.
• Marlen Manufacturing and Development Co v. Commissioner: Lead counsel for a challenge to a proposed change in an accounting method, adjustments to gross receipts for multiple years and additions to tax.
• Austin Powder Company, William and Deborah Davis v. Commissioner: Lead counsel for a challenge to the valuation of gifts made of the stock of a closely held business, Austin Powder Company. IRS has recently  agreed to concede the case in full and the decision documents are in the process of being prepared.
• GS Manufacturing, Inc. v. Commissioner: Lead counsel for a challenge to an insurance premium deduction for a captive insurance program, and related additions to tax.
• Harold & Bernice  Kahn v. Commissioner: Lead counsel for a challenge to a net operating loss carryback, the re-characterization of a long-term capital gain to a passive foreign investment company income and related additions to tax.
• Modern Silicone, Inc., v. Commissioner: Lead counsel for a challenge to an insurance premium deduction for a captive insurance program, and related additions to tax.
• One South State Street, LLC, One South State Street LLC, Tax Matters Partner v. Commissioner: Lead counsel in a challenge to developer fees being disallowed as qualified rehabilitation expenses.

Career history

• Tax partner, Chair of Tax Controversy & Litigation Group, Baker Hostetler, 2008-2015
• Tax partner, Thompson Hine, 2000–2008
• Managed IRS Practice & Procedure Group in Cleveland, Akron/Canton and Toledo Ernst & Young offices, 1999 and 2000
• Tax counsel, Cliffs Natural Resources, 1997–1999
• Internal Revenue Service, 1988–1997
  • Senior tax attorney for chief counsel
  • Counsel for Utilities Industry Specialization Program, 1990–1997