John Porter is a Senior Partner and Partner-In-Charge of the Houston Office who handles federal gift, estate and income tax litigation and controversy work. He is nationally recognized for his expertise in representing taxpayers before and against the Internal Revenue Service in estate and gift tax controversies, especially those involving hard-to-value assets such as interests in family limited partnerships and limited liability companies.
Mr. Porter has served as lead counsel for taxpayers in numerous cases in the United States Tax Court, the Court of Federal Claims, United States District Courts and Courts of Appeals. He also has represented taxpayers in numerous other federal tax audits and administrative appeals. He frequently advises and represents fiduciaries and beneficiaries of trusts and estates with respect to administration and fiduciary duty issues.
Mr. Porter is a Fellow and a former Regent of the American College of Trust and Estate Counsel. He is also the former chair of the Tax Litigation and Controversy Section of the American Bar Associaton's Real Property, Probate & Trust Section.
Publications, Speeches and Presentations
- “A Formula for Avoiding Transfer Tax Litigation?” Willamette Management Associates Insight, Autumn 2010
- “Defined-Value Transfer Planning After McCord and Christiansen,” Probate & Property, September/October 2008 (Stephen T. Dyer, co-author)
- “H.V. Kohler, Jr.: Lessons From the Trenches in a Valuation Dispute,” Journal of Practical Estate Planning, October/November 2006
- “Litigation of the Transfer Tax Dispute: Does the Forum Really Matter?” Journal of Practical Estate Planning, June/July 2006
- “The Transfer Tax Audit: The Beginning of the Litigation Discovery Process,” Journal of Practical Estate Planning, February/March 2006
- “Strangi and Schutt: The Code Sec. 2036 Battles Continue,” Journal of Practical Estate Planning, October/November 2005
- “FLP Wars Update,” Trusts & Estates, July 2005
- “W.C. Bongard Est.: The Entire Tax Court Weighs In on the Code Sec. 2036 Battles Regarding Family Limited Partnerships,” Journal of Practical Estate Planning, June/July 2005
- “Buy-Sell Agreements: True Provision Does Not Control Value for Estate Tax Purposes,” CCH Business Valuation, Vol. 6, Issue No. 3, April 2005
Speeches and Presentations
Frequent speaker at tax and estate planning seminars for numerous organizations, including:
- University of Miami Heckerling Institute on Estate Planning
- Southern California Tax and Estate Planning Forum
- New York University Institute on Federal Taxation
- USC Gould School of Law Tax Institute
- UCLA-CEB Estate Planning Institute
- Great Western Tax and Estate Planning Conference
- Notre Dame Tax and Estate Planning Institute
- The University of Texas Annual Taxation Conference
- Washington State Bar Association Annual Estate Planning Seminar