Hi There !

A client of mine has been tussling with the IRS over a tax shelter from 1999.
The IRS made him an offer, and given him until Monday (3 days from
now!) to take it or leave it.  I have no expertise in this
area----help!

A 5-star answer would be the names and phone numbers of 2 high-end
(big dollar) attorneys in Chicago who specialize in this area: 
deciding whether or not to fight the IRS in court.

Please note there is apparently a difference between "regular" tax
attorneys and "specialized" tax attorneys.  The latter specialize in
litigating very complicated tax shelters for wealthy individuals.  A
5-star answer would include two attorneys in this "specialized"
category----not the "regular" tax attorney who gives "regular" tax
advice.

All comments greatly appreciated !

ron

P.S.   The original tax shelter was set up by Ernst & Young.  My
client wants a personal attorney separate from the E&Y corporate
attorney.

P.P.S.  If I could get the answer by 2 PM (PST), that would be great. 
Earlier would be even better.  Thanks!

Hello Ron,

Below you will find the results of my research for high-end tax
attorneys in Chicago

George B. Javaras, P.C.    
Kirkland & Ellis'

?George Javaras is a senior tax partner who represents major
multinational corporations in acquisitions, dispositions, spin-offs,
joint ventures, tax planning (including executive compensation) and
tax controversies.  He has structured a large variety of multi-billion
dollar acquisitions and dispositions (both domestic and cross-border,
taxable and tax-free) and planned substantial bankruptcy
restructurings.  In addition, he has represented a major commodities
exchange on its tax matters.  His clients are engaged in financial
services, manufacturing, natural resources, metal refining,
advertising, insurance, communications, transportation, food and
apparel, among other industries.?

?In Chambers USA 2004 edition of America's Leading Lawyers for
Business, George is listed among the #1 leading tax practitioners in
Chicago.  Described as "one of the country's leading lights" and a
"premier tax lawyer," George is renowned for his involvement in
structuring a variety of multi-billion dollar acquisitions and
dispositions.  He was also listed as a top tax attorney in the 2001,
2002 and 2003 editions of the directory?

?In addition, he was listed by Law Business Research as a leading tax
practitioner in The International Who's Who of Corporate Tax Lawyers. 
The International Tax Review's 2002 international research survey
entitled "Guide to the World's Leading Tax Advisers" names George as a
leading adviser in his field.?

T:  312-861-2016
F: 312-861-2200 
Email: gjavaras@kirkland.com

Kirkland & Ellis'
http://www.kirkland.com/ourFirm/lawyerBio.aspx?InfiniumH4ID=4672&employeeH4ID=24336&attorneyH4ID=8704

Kirkland & Ellis LLP 
Aon Building 
200 East Randolph Drive 
Chicago, IL 60601-6636 
Tel: +1 312 861 2000 
Fax: +1 312 861 2200 
Website: www.kirkland.com 
Email: wkirsch@kirkland.com
http://www.chambersandpartners.com/us/Default.asp?action=rf&rf=fprofile&fid=3636

?George Javaras was described to researchers as "one of the country's
leading lights" in the area of tax law. He cultivates a universally
respected practice focused primarily on transactional tax matters for
large corporate clients, including Alcoa and Sara Lee. Celebrated for
his "photographic memory" and sure handling of M&A and cross-border
trade concerns, Javaras is considered in some quarters to be the
"premier tax lawyer" in the USA. Also hailed as "one of the top tax
and corporate lawyers in the country,"

Chambers  & Partners
http://www.chambersandpartners.com/us/?action=frame&lf=sfrt&rf=spe&eid=121


Clients at Kirkland & Ellis 
http://www.kirkland.com/ourFirm/clients.aspx


In Chambers' 2003-2004 review of national legal talent in the area of
"Tax," the lawyers at Kirkland & Ellis are listed among the best in
the country.

Excerpt from Chambers & Partners:  America's Leading Business Lawyers 2003-2004:

George Javaras 
?George Javaras remains accepted as one of the market leaders in
Chicago. He advised on the tax aspects of the restructuring of the
Chicago Board of Trade and acted on the acquisition of Bcom3 Group by
Publicis Groupe.?

Jack Levin
? Jack Levin "may be the best tax lawyer in the world," according to
his contemporaries. A trailblazing academic, as well as an outstanding
tax practitioner, he is credited with writing "the definitive tax
treatise." Although he also channels much of his time into private
equity work, he continues to oversee the progress of his talented tax
team.?

Jeff Sheffield 
?Among them is Jeff Sheffield, whose "ability to separate what's
important from what isn't" is held in the highest regard. He handled
the tax implications of the high-profile $25 billion DIRECTV spin-off.
Reputed to possess a "photographic memory,"

Don Rocap 
?Former Government attorney Don Rocap still has a particularly notable
public sector tax practice. Peers regard him as a "creative and
analytical" attorney, who "stays right on top of the issues."

Bill Welke 
?Respected transactional lawyer Bill Welke was also endorsed to
researchers for his "good, practical deal sense."

The Clients: 
Vestar Capital Partners; GKN; Bain & Company; Leo Burnett McManus; GM;
Sara Lee; United Airlines; USG; CNA Financial; Bcom3 Group; Chicago
Board of Trade; Alcoa and Navistar International.

Kirkland & Ellis 
http://www.kirkland.com/ourFirm/newsListDetail.aspx?H4AssetID=1123481220&type=Articles


From the Chamber?s USA website:

Kirkland & Ellis LLP

?The firm's tax group, comprising approximately 20 lawyers, retains a
strong reputation for contested tax issues connected with challenges
by the IRS and other state and federal authorities. However, it is in
the area of tax planning and transactional advice that it particularly
stands out. Competitors can only admire the group's "excellent
clients" and "tremendous strength," while clients themselves praise
this "smart group of guys" for its "prompt, thorough, and effective"
service. The firm's profile for international work is continuing to
expand.?
http://www.chambersandpartners.com/us/?action=frame&lf=sfrt&rf=spe&eid=121


Here is the listing of Chambers & Partners Ranked Attorneys 
Category: Illinois - Tax
http://www.chambersandpartners.com/us/Default.asp?action=lf&lf=sprt&eid=121


Here is the listing of Chambers & Partners Ranked Firms 
Category: Illinois - Tax
http://www.chambersandpartners.com/us/Default.asp?action=lf&lf=srt&eid=121


Search criteria:
"Top tax attorney"
Chicago tax attorney OR lawyers best
Chambers USA 2004

I hope you find this helpful! 

Best regards,
Bobbie7

Thanks, bobbie7 !

ron

Ron --

As I recall, I recommended Baker & McKenzie to you for another client
of yours.  While that eminent firm may not be the one you need this
time, because its practice has a heavy (but not exclusive) emphasis on
international matters, it is interesting to note that one of its very
senior partners (newly retired) has signed on for a stint at the IRS
"to help coordinate the agency's efforts to combat abusive tax
shelters and improve enforcement processes":
IRS: Klotsche Named Senior Advisor (10/6/03)
http://64.233.167.104/search?q=cache:YSHfurTsMoAJ:www.irs.gov/pub/irs-news/ir-03-115.pdf+klotsche&hl=en

Your client may find it useful (if there is time) to call one of the
of Baker firm's tax partners in Chicago to see if they are equipped to
advise your client on such short notice or to recommend a specialist
in tax litigation for high net-worth individuals that the Baker firm
gas worked with in the past.  Everything else being equal, who better
to call that a major Chicago firm that has had a long relationship
with a tax lawyer who is advising the IRS commissioner on tax shelter
issues?

Here is a list of the firm's tax lawyers, with contact information:
Baker 7 McKenzie: Tax Controversy and Litigation Attorneys
http://www.bakernet.com/BakerNet/Practice/Tax/Tax+Controversy+Litigation/Description/default.htm

markj-ga

George Javaras was one of the brightest tax attorneys I have known in
nearly 30 years.  He will be sorely missed in this life.  All of the
other K&E attorneys listed are A+++

markj & taxgeek,

Thanks to you both.  This IRS negotiation is an ongoing process for my
Chicago client;  I will forward your comments to him ASAP.

Thanks again!
ron