Two Hull McGuire Lawyers Appointed To IRS Tax Shelter Panel
Washington, D.C., 2/20/2003 - Two attorneys with
Hull McGuire PC, a law firm based in Pittsburgh with offices in San Diego
and Washington, D.C., have been selected by the Internal Revenue Service
(IRS) to serve as arbitrators on a special IRS tax arbitration panel.
Julie McGuire, a tax lawyer in Hull McGuire's Pittsburgh
office, and Albert Sturtevant, a corporate and securities lawyer in its
Washington, D.C. office, were appointed to serve as neutral arbitrators in
contingent liability tax shelter cases under Section 351 of the federal
tax code.
On January 27, 2003, the IRS announced its selection of
thirty individuals to serve as qualified neutral arbitrators available to
taxpayers for arbitration of the tax shelter cases. The panel
was selected from recommendations of the American Arbitration Association
(AAA), which maintains a roster of over 9,000 trained and qualified
neutral arbitrators. According to the IRS, the appointments
were made on the basis of experience and expertise in the federal income
tax code.
Section 351 transactions are shelters in which taxpayers
use a subsidiary to generate both loss-creating stock transfers and
certain payments, thereby creating a double tax deduction. The
IRS has targeted this type of tax shelter, frequently offered by promoters
who acquire fees for selling interests in the shelter, as a potentially
abusive tax shelter. Taxpayers have until March 5, 2003 to
apply to the IRS for arbitration of a tax shelter dispute under Section
351.
Julie McGuire is a shareholder and co-founder of Hull
McGuire who graduated first in her class from both Carnegie Mellon
University and Duquesne Law School. Prior to forming Hull
McGuire, she was Tax Counsel at Alcoa, Inc.
Albert Sturtevant is a native of Washington, D.C. and a
graduate of Yale Law School. Before entering private practice
in 1973, he served in the Securities and Exchange Commission's Division of
Market Regulation. He is of counsel to Hull McGuire.