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· Lead counsel in Apple Computer, Inc. v. Commissioner, 98 T.C. 218 (1992): R&D tax credit includes stock compensation. Complete taxpayer victory; attracted national attention; was worth hundreds of millions of dollars to the high-tech industry.
· Xilinx Inc. v. Commissioner, Tax Court Docket No. 4142-01: Role of stock compensation in R&D cost-sharing arrangements -- the most significant high-tech tax issue since Apple Computer. Lead representative in motion for summary judgment in Feb. 2002.
· Lead counsel in Charles Schwab Corp. v. Commissioner, 107 T.C. 283 (1996): taxpayer victory re accrual of California franchise tax as federal deduction.
· Lead counsel in Charles Schwab Corp. v. Commissioner, 122 T.C. 191 (2004) (rare outright taxpayer victory in valuation issue), 123 T.C. 306 (2004) (partial win on franchise tax issue).
· Favorable IRS technical advice approving taxpayer election to capitalize one R&D project while expensing others. TAM 9623003 (Feb. 12, 1996), CCH ¶ 12,047.12; RIA ¶ 1745.02(37).
· Lead counsel in Robert Half International, Inc. v. Franchise Tax Board, 66 Cal.App.4th 1020 (1998): trial court reversed; nationally recognized precedent re California interpretation of UDITPA definition of “nonbusiness” income/loss.
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