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Michelle Abroms Levin

Of Counsel
Huntsville
mlevin@sirote.com
Tel: 256-518-3605
Assistant
Abigail Burke
256-518-3653
aburke@sirote.com

Michelle is a member of the firmís Tax Controversy Practice Group. She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims and, federal district court. Her experience includes a wide range of complex tax issues. Prior to joining Sirote, Michelle worked as a trial attorney at the Tax Division of the Department of Justice where she represented the United States in federal district court.

  • Extensive knowledge of subjects related to federal tax practice and procedure
    and the handling of tax controversies and litigation.
  • Represents clients during all phases of federal tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, and federal district court.
  • Experience includes a wide range of complex tax issues, including economic substance and business purpose, partnership issues, OID, transfer pricing, accuracy-related penalties, foreign tax credits, and criminal tax issues.
  • Previously worked as a trial attorney at the Tax Division of the Department of Justice, representing the United States in federal district court in Alabama, Georgia, and Florida in a wide variety of tax cases, including refund, bankruptcy, and preparer-injunction cases.
  • Admitted to U.S. Tax Court and U.S. Court of Federal Claims
  • State Bar of Alabama
  • State Bar of Georgia
  • District of Columbia Bar
  • Representative Cases
    • GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner, U.S.Tax Court Docket Nos. 18940-08 and 18941-08 (decision entered Oct. 4, 2010.) (Debt/equity, OID case fully conceded by IRS)
    • Fidelity International Currency Advisor A Fund, L.L.C. v. United States, No. 05-40151 & 06-40130 (D. Mass.); Fidelity High Tech Advisor A Fund, L.L.C. v. United States, Nos. 06-4-243 & 06-40244 (D. Mass.) (45-day trial on variety of issues including economic substance, TEFRA and tax treatment of contingent obligations)

Schools

  • University of Texas School of Law
    J.D., 2005
  • Washington University, Olin School of Business
    BSBA, magna cum laude, 2002

Additional Accolades

University of Texas School of Law

  • Texas International Law Journal, Staff Editor
  • James A. Elkins Memorial Scholarship

Washington University, Olin School of Business

  • William S. Krebs Accounting Award

 

 

 

 

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