Jon D. Feldhammer

Partner

Jon Feldhammer

San Francisco

P: +1.415.291.6212
F: +1.415.291.6312
  • Represented corporate and partnership clients before the IRS Exam and IRS Appeals involving section 48 investment tax credit (“ITC”) challenges with resolutions including no-changes and settlements at significantly reduced adjustments.
  • Negotiated favorable settlements for corporate clients with IRS Exam regarding meals provided to employees.
  • Successfully resolved partnership cases including disguised sales, at-risk rules, and disproportionate distributions.
  • Successfully resolved individual cases involving charitable deductions and assignment of income arguments before IRS Appeals.
  • Litigated estate and gift taxes issues including valuation, split-dollar arrangements, and family limited partnerships (“FLPs”).
  • Litigated FBAR penalties.
  • Litigated multiple cases involving bad debt and worthless securities.