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Thomas & Libowitz Announces New Member of the Firm
January 27, 2009
 We are pleased to announce that Gerald W. Kelly has joined Thomas & Libowitz as part of our strong and well recognized Tax Practice Group.
Jerry has devoted his legal career to representing clients entangled in major disputes with the Internal Revenue Service (the "IRS"), and has represented businesses and individuals before the agency's Collection, Examination, and Appeals Divisions. Jerry also represents clients that are the targets of criminal tax investigations.
Tax litigation is a significant part of Jerry's practice. He represents clients involved in litigation before the U.S. Tax Court, where he has tried numerous cases and settled many more. He has also argued before the U.S. Circuit Court of Appeals. In the U.S. District Courts, Mr. Kelly has represented clients involved in a wide variety of civil and criminal matters.
Jerry began his professional career with the IRS in 1991, where he was assigned to field offices in the Washington, D.C. metropolitan area. As a Revenue Officer, Jerry was responsible for civil investigations and enforcement actions. He was also trained as an Offer in Compromise Examiner and evaluated settlement proposals submitted by individual and corporate taxpayers.
Jerry has been interviewed on ABC News concerning IRS procedures and has also provided commentary to CNN, The Washington Post, The Washington Times and other major news sources. He has also been a guest lecturer on IRS controversies at the University of Baltimore and the Maryland Volunteer Lawyers Service.
Some of the specifics of Jerry's practice area are listed below.
IRS Collection Matters- Offers in Compromise
- High Income Non-Filers
- Collection Due Process Appeals
- Penalty and Interest Abatements
- Levy Releases
- Subordinations/Discharges of Tax Liens
- Innocent Spouse Claims
- Trust Fund Recovery Penalty Assessments
- Estimated (SFR) Tax Assessments
- Installment Agreements
- Lien Releases
- Fraudulent Conveyances
- Expired Collection Statutes
- Improper Levy/Seizure Action
Civil Tax Litigation- Disallowance of Business
- Expenses
- Civil Fraud Penalty
- Fraudulent Conveyances
- Collection Due Process
- "Hobby Loss"
- Employee/Independent Contractor Status
- Innocent Spouse
- Liability for Trust Fund Recovery Penalty
- Unreported Income
- "Like-Kind" Exchange
- Unlawful Collection Actions
- Freedom of Information Act Requests
- Tax Lien to Judgment
- Non-Filers/Estimated Tax Assessments
- Shareholder Basis
- R & D Expenses
Criminal Tax Matters- Tax Evasion
- Tax Return Preparers
- Willful Failure to File
- Laundering Narcotics Proceeds
- Money Laundering
- Plea Agreements
- Structuring of Financial Transactions
- Sentencing Guidelines Issues
- Obstruction of the IRS
- Voluntary Disclosures
- Unreported Income
- Inflated Expenses/Deductions
- False Statements on Tax Return
- Tax Loss Calculations
IRS Audits
- Unreported Income
- Civil Fraud Penalty
- “Hobby-Loss"
- Partnership Issues
- Disallowed Business Expenses
- Real Estate Transactions
- Characterization of Income
- Abusive Trust Arrangements
If you have questions, please contact:
Steven A. Thomas, Esquire
SThomas@TandLLaw.com
(410) 752-2468
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