Area(s) of Expertise
Brent Gardner advises clients with respect to tax controversy resolution, including litigation and litigation avoidance. Mr. Gardner has experience with state and federal tax controversies and represents both businesses and individuals.
In addition to his tax controversy practice, Mr. Gardner counsels public and private companies regarding their existing operations, with particular emphasis on mergers, acquisitions and reorganizations.
Clients and Matters
Mr. Gardnerís representative experience includes:
- Representing clients in tax cases heard in U.S. District Court, U.S. Tax Court and the Texas Court of Appeals.
- Representing clients in administrative proceedings with the IRS, including audit and appeals.
- Representing individuals making voluntary disclosures related to interests in offshore financial accounts and entities.
- Preparing private letter ruling requests on various issues, including the deductibility of a charitable contribution of a conservation easement.
- Preparing tax opinions, representation letters and tax disclosure statements related to tax-free corporate mergers and acquisitions.
- Preparing partnership agreements and limited liability company agreements.
- Performing due diligence, including extensive document review in English and Portuguese.
- LL.M. in Taxation, New York University School of Law (2008)
- J.D., University of Iowa College of Law, with distinction (2006)
- B.S., Arizona State University, magna cum laude (2004)
- Member, Beta Gamma Sigma
Publications and Speeches
- Co-Author, All That Glitters Is Not Gold...Entering Into and Enforcing Charitable Pledges in Texas, Tex. Tax. Law., Winter 2010.
- Co-Author, Bringing It All Back Home: Unreported Offshore Assets (presented at 57th Annual University of Texas Taxation Conference) (November 2009).
- Co-Author, FIN 48 and Related Privilege Issues (presented at 56th Annual University of Texas Taxation Conference) (November 2008).
- Co-Presenter with Val J. Albright and Michael J. Donohue, Address at Lane Gorman Trubitt PLLC: Current Trends and Traps in Federal Tax Controversies (August 2012).
- Co-Presenter with John Woodruff, Address at Tax Executives Institute Houston Chapter International Roundtable: Permanent Establishment (March 2012).
- Co-Presenter with Val J. Albright, Address at BNA Tax & Accounting Council for International Tax Education: Transfer Pricing Controversy and Competent Authority (July 2011).
- Admitted to practice before:
- Texas State Courts
- U.S. District Court for the Southern District of Texas
- U.S. Court of Federal Claims
- U.S. Tax Court
- Member, State Bar of Texas
- Member, Dallas Bar Association