• LL.M. (Taxation), Washington University (2015)
• J.D., University of Missouri—Columbia (2003)
• B.S, Business Administration, University of Missouri—Columbia (with honors) (1999) 

• Missouri
• Illinois
• U.S. District Courts
  • Eastern District of Missouri
  • Western District of Missouri
  • District of Colorado
• U.S. Tax Court

• Bar Association of Metropolitan St. Louis, previously served as President and Tax Section Chair
• American Bar Association, Section of Taxation, Vice-Chair of Civil and Criminal Tax Penalties Committee
• Women in White Collar Defense Association
• Federal Bar Association
• Women Lawyers’ Association of Greater St. Louis
• St. Louis Lawyers Association
• St. Louis County Bar Association
• Missouri Bar

• Sentencing in Tax/White Collar Cases – Views from the Bench – U.S. District Court Judges. Summer Tax Summit in St. Louis hosted by the St. Louis Chapter of the Federal Bar Association. (August 2023)
• Flipping The Script: Putting The Government On Defense At Trial. 15th Annual NYU Tax Controversy Forum. New York City, NY. (2023)
• Presenting Transactions in Tax Court – A Discussion with Tax Court Judges, with a Focus on Planning for and Litigating Self Employment Tax Issues. May Meeting. American Bar Association | Tax Section. Washington, D.C. (2023)
• Only Two Things Are Certain and This Isn’t About Death: Defending Criminal Tax Cases. West Coast White Collar Conference. San Diego, CA. (2022)
• Challenging the Application of Tax Penalties: Accuracy and Civil Fraud. Forensic Accounting Summit: Forensic Accounting and Reconstruction. Virtual. (2022)
• You’ve Got a Friend: Why Male Leaders Should Mentor Women. Women in the Profession Spring CLE. The Missouri Bar. Webinar. (2022)
• IRS Undeterred: An Update on Criminal Tax Enforcement. National Institute on White Collar Crime. American Bar Association | Criminal Justice Section. Miami, FL. (2021)
• What is Tax Fraud and Why Does it Matter? Tax Controversy Forum. NYU School of Professional Studies. (2021)
• Non-Filers. Virtual Criminal Tax Day Event. IRS Representation Conference. (2021)
• Important Criminal Developments – Civil and Criminal Tax Penalties Committee. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Virtual. (2020)
• Employment Tax: Your Client’s Legal Obligations and the Risks of Noncompliance. Missouri Bar. Virtual. (2019)
• Plenary: Ethical Issues When Representing the Accountant in an IRS Service Investigation. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2019)
• Employment Tax: Legal Obligations and the Risks of Non-Compliance. 15-Hour MCLE Update. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2019)
• Important Criminal Developments – Civil and Criminal Tax Penalties Committee. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2019)
• Important Criminal Developments – Civil and Criminal Tax Penalties Committee. Midyear Tax Meeting. American Bar Association | Tax Section. New Orleans, LA. (2019)
• Criminal Tax Workshop. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2018)
• Women and Wealth Panel Discussion. BeSEEN Meeting. Mueller Prost. St. Louis, MO. (2018)
• Preparing Your Client (the Taxpayer) for the Government Interview. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Atlanta, GA. (2018)
• Your Client Just Dumped a Pile of Unopened IRS Notices on Your Desk – Now What? 15-Hour MCLE Update. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2018)
• Ethics Issues in Criminal Representations and Fraud Examinations. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2018)
• Important Criminal Developments – Civil and Criminal Tax Penalties Committee. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2018)
• Hot Topics in Tax Fraud. Multi-Track Conference. Institute of Internal Auditors & Association of Certified Fraud Examiners | St. Louis Chapter. St. Louis, MO. (2018)
• Civil Fraud and Accuracy Penalties: Strategies for The Administrative Appeal and Litigation. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2017)
• Employment Tax Enforcement by the Department of Justice and Internal Revenue Service in 2017. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2017)
• Can’t Get There from Here: Passport Restrictions for Seriously Delinquent Tax Debtors. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Austin, TX. (2017)
• Hot Topics in Civil and Criminal Federal Tax Enforcement. 15-Hour MCLE Update. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2017)
• Addressing Employment Tax Issues in Sensitive Examinations. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2016)
• Ethical Considerations in IRS Settlement Negotiations. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Boston, MA. (2016)
• “What Do You Mean My Spouse Hasn’t Been Paying Our Taxes?!?”: When Family, Tax and Criminal Law Intersect. Family Law Conference. Missouri Bar. Branson, MO. (2016)
• Orange is Not the New Black: Defending the Alleged Tax Fraudster. 15-Hour MCLE Update. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2016)
• Practical Considerations for Taxpayer Representation in Criminal Tax Investigations. Federal Tax Conference. Illinois State Bar Association. Chicago, IL. (2016)
• IRS Penalty Collections: How to Protect Your Client’s Rights. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2015)
• Tax Preparer Fraud: Strategies for Defending the Tax Preparer or Promoter in Criminal and Civil Injunction Litigation. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Chicago, IL. (2015)
• “My Spouse Hasn’t Been Paying Our Taxes?” A Practitioner’s Guide to Representing the Innocent Spouse. Solo and Small Firm Conference. Missouri Bar. Branson, MO. (2015)
• Handling Cases with Potential Criminal Issues. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2015)
• Important Developments on Civil Penalties – Civil and Criminal Tax Penalties Committee. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2015)
• Effective Representation During an Eggshell Audit–Avoiding A Criminal Referral and Civil Fraud Penalty. Federal Tax Conference. Illinois State Bar Association. Chicago, IL. (2015)
• Summons Enforcement–Procedure, Privileges, and Petitions to Quash. Midyear Tax Meeting. American Bar Association | Tax Section. Houston, TX. (2015)
• Ethical Considerations in Tax Controversy. Tulane Tax Institute. New Orleans, LA. (2014)
• Important Developments on Civil Penalties – Civil and Criminal Tax Penalties Committee. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2014)
•  Important Developments on Civil Penalties – Civil and Criminal Tax Penalties Committee. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Denver, CO. (2014)
• The IRS Collection Process: What You Need to Know to Advise Your Clients. American Bar Association | Tax Section. Webinar. (2014) Cooked Books: A Recipe for Representing a Client with a Potential Criminal Tax Problem. Solo and Small Firm Conference. Missouri Bar. Branson, MO. (2014)
• “My Client Just Dumped a Large Pile of Unopened Mail on my Desk…From the IRS”: Practical Tips for the Non-Tax Lawyer When Representing a Client with a Federal Tax Problem. Bench and Bar Conference. Bar Association of Metropolitan St. Louis. Lake of the Ozarks, MO. (2014)
• Nuts and Bolts Series: Trying Cases Before the Tax Court. May Tax Meeting. American Bar Association | Tax Section. Washington, D.C. (2014)
• When Tax Fraud and Trust and Estate Administration Intersect: Avoiding an IRS Criminal Investigation and the Assertion of a Penalty for Civil Fraud. Fiduciary Litigation Seminar. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2014)
• Important Developments on Civil Penalties – Civil and Criminal Tax Penalties Committee. Midyear Tax Meeting. American Bar Association | Tax Section. Phoenix, AZ. (2014)
• Important Recent Updates in Criminal Tax Fraud and Civil Tax Controversy. St. Louis Tax Update. Bar Association of Metropolitan. St. Louis, MO. (2014)
•  Dialing for Dollars: The IRS Collection Process-Administrative and Judicial Solutions. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2013)
• Navigating the Ethical Minefield and Keeping Your C.P.A. License! Practical Advice for Avoiding Ethical Concerns in Your Tax Practice and Properly Handling Them When They Arise. Missouri Society of Certified Public Accountants | St. Louis Chapter. St. Louis, MO. (2013)
•  “My ‘Soon-to-be Ex’ is a Tax Cheat!”: Effectively Representing the ‘Innocent Spouse’ During Divorce Proceedings. Family Law Conference. Missouri Bar. Branson, MO. (2013)
• Administrative Tax Strategies and Techniques in a Recessionary Economy. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2012)
•  An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies. Midyear Tax Meeting. American Bar Association | Tax Section. Orlando, FL. (2013)
• An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies. American Bar Association. Webinar. (2013)
• Vanishing Time Limits for Equitable Relief. Midyear Tax Meeting. American Bar Association | Tax Section. Orlando, FL. (2013)
• When Clients with Tax Problems Cause Problems for You: Ethical Issues in Tax Practice. American Society of Women Accountants and St. Louis Society of Women Certified Public Accountants. St. Louis, MO. (2010)
• When Clients with Tax Problems Cause Problems for You: Ethical Issues in Tax Practice. Missouri Society of Certified Public Accountants | St. Louis Chapter. St. Louis, MO. (2009)

• “When Failing to Pay Taxes Becomes a Federal Crime.” St. Louis Bar Journal. (2018)
• “The High Stakes of Payroll Tax Fraud.” St. Louis Bar Journal. (2016)
• “Whether the IRS Alleges That Your Client Is a Fraudster or Just Plain Negligent, In Tax Court Litigation the Penalties Shouldn’t Be an Afterthought.” Journal of Passthrough Entities. (2015)
• “Resisting Enforcement of an IRS Administrative Summons After the Supreme Court’s Recent Ruling in U.S. v. Clarke.” Journal of Passthrough Entities. (2014)
• “Avoiding an IRS Criminal Investigation and Tax Fraud Prosecution: Effectively Representing Your Client in an ‘Eggshell Audit.’” St. Louis Bar Journal. (2013)

Past results do not guarantee future results.

• Persuaded the Department of Justice to close its tax evasion investigation of a small business owner who allegedly failed to report several hundred thousand dollars in income.
• Persuaded the Department of Justice to decline to prosecute an accountant who IRS-Criminal Investigation maintained had aided and assisted in the preparation of fraudulent tax returns in violation of 26 U.S.C. § 7206(2).
• Represented a business owner who had not filed income or employment tax returns for several years and paid all employees in cash. Assisted client in coming into compliance with the tax laws, and avoided an IRS criminal investigation and prosecution.
• Following a lengthy IRS criminal tax investigation into the alleged efforts of a business owner to evade IRS Collection’s efforts to collect delinquent tax liabilities, persuaded the Department of Justice to decline prosecution.
• Persuaded the Department of Justice to terminate its tax evasion investigation of a business owner who allegedly evaded the efforts of the IRS Collection to collect past due employment taxes.
• Represented an accountant charged with multiple counts of aiding and assisting in the preparation of fraudulent tax returns in violation of 26 U.S.C. § 7206(2). Successfully negotiated a favorable plea agreement resulting in a sentence of home-confinement.
• Represented a business owner with a professional license in a case involving a fraudulent tax return that generated a large tax refund. Successfully negotiated a favorable plea agreement resulting in a sentence of probation and persuaded state licensing board to allow client to maintain licensure.
• Represented a business owner who underreported income by over $1 million. Client came into compliance with the tax laws and avoided an IRS criminal investigation and prosecution.
• Represented a tax return preparer in a grand jury investigation involving the preparation of dozens of allegedly false and fraudulent tax returns. Negotiated a favorable plea agreement resulting in a sentence of probation.
• In a multi-year tax evasion investigation, successfully utilized the IRS’s Expedited Plea Program to mitigate against the likelihood of a lengthy prison sentence. Client received a sentence of probation.
• Represented a bookkeeper in a multi-year criminal tax investigation related to the alleged failure to file employment tax returns and pay employment taxes. IRS-Criminal Investigation ultimately declined to recommend charges to the Department of Justice.
• Represented a small business owner in a multi-year IRS tax evasion investigation. Negotiated a plea agreement whereby the tax loss was significantly limited and despite the Department of Justice seeking a two-year prison sentence, persuaded court to sentence client to probation.
• In the case of an individual taxpayer who had claimed excessive and unsubstantiated deductions on the return, resolved audit with minimal adjustments and no fraud penalty.

Past results do not guarantee future results.

• Successfully challenged IRS Notices of Deficiency alleging millions of dollars in tax deficiencies on behalf of a Missouri business and individual in a trial before the U.S. Tax Court. The Court held completely for our clients and ordered the IRS to pay attorneys’ fees.
• Represented a tax attorney/C.P.A. in an IRS investigation involving the promotion of abusive tax shelters. Persuaded the IRS’s Examination Division to close its investigation without the assertion of any penalties.
• Represented a corporation in a case pending before the U.S. Tax Court where the IRS alleged the corporation owed $750,000 in additional income tax, penalties and interest. The IRS ultimately conceded all additional income tax except for approximately $90,000.
• Substantially prevailed after a U.S. Tax Court trial on behalf of an individual taxpayer who was an innocent spouse under 26 U.S.C. § 6015, avoiding over $200,000 in taxes, penalties and interest.
• Persuaded the IRS Examination Division to grant innocent spouse relief for an individual under 26 U.S.C. § 6015, avoiding over $7 million in taxes, penalties and interest.
• Represented an accounting firm in an IRS investigation involving its alleged participation in tax avoidance transactions. Persuaded the IRS Office of Appeals to completely concede hundreds of thousands of dollars in proposed penalties asserted under 26 U.S.C. § 6694(b).
• Persuaded the IRS’s Examination Division to abandon its determination that taxpayer’s farming operations were not conducted for profit under 26 U.S.C. § 183.
• Represented a physician and business owner in an IRS income tax appeal involving proposed adjustments of over $1 million due to alleged unreasonable compensation. Persuaded the IRS Office of Appeals that compensation was reasonable, resulting in additional tax due of less than $10,000.
• In a case pending before the U.S. Tax Court, persuaded the IRS Office of Appeals, that despite corporate and individual clients entering into allegedly abusive tax transactions, the previously asserted $1.5+ million civil fraud penalties under 26 U.S.C. § 6663 were unwarranted.
• Persuaded the IRS to abate $250,000 in tax penalties previously asserted for corporation’s alleged failure to properly file employment tax returns using magnetic media.
• Represented a manufacturing company in an IRS Income Tax Examination involving the capitalization of expenses under 26 U.S.C. § 263A. Persuaded the IRS that the company’s accounting methods clearly reflected income and client received a refund.
• Persuaded the IRS Office of Chief Counsel, in a matter pending before the U.S. Tax Court, to grant innocent spouse relief to an individual client under 26 U.S.C. § 6015, thereby avoiding a $2+ million tax deficiency.
• Represented a medical professional and business owner before the IRS Office of Appeals to challenge the IRS Examination Division’s findings that he did not “materially participate” in his business under 26 U.S.C. § 469. Persuaded the IRS that he met the requirements for material participation resulting in the allowance of tax losses and substantial tax savings.
• Persuaded the IRS Office of Appeals and IRS Office of Chief Counsel that civil fraud penalty asserted pursuant to 26 U.S.C. § 6663 by IRS Examination Division was unwarranted despite client’s prior guilty plea to a criminal tax offense.
  Persuaded the IRS Examination Division to remove previously asserted penalties for civil fraud under 26 U.S.C. § 6663.
• Represented accountant in preparer penalty investigation involving 26 U.S.C. §§ 6700 and 6701 and persuaded the IRS Examination Division that penalties were unwarranted.
• Represented franchisee of one of the largest tax preparation companies in the United States in a civil injunction action brought by the Tax Division of the U.S. Department of Justice. Successfully negotiated an agreement whereby the franchisee was able to continue operating its tax preparation business, and also resolved related IRS Office of Professional Responsibility proceedings.
• Represented an attorney who, despite substantial income from his law practice failed to file returns for several years. Persuaded the IRS to abate hundreds of thousands of dollars in penalties due to reasonable cause.
• Represented C.P.A. in IRS preparer penalty investigation and appeal of penalties under 26 U.S.C. § 6694(b). Persuaded the IRS Office of Appeals to completely concede all penalties.
• In a case involving over $200,000 in civil penalties asserted pursuant to 26 U.S.C. § 6721 and 6722 for failure to file correct information returns and failure to furnish correct payee statements related to the Affordable Care Act, persuaded the IRS that all penalties should be abated.
• Represented a professional in her claim for innocent spouse relief through the IRS’s administrative process and before the U.S. Tax Court. Reached a favorable resolution resulting in a concession by the IRS of 80 percent of the tax due and over $250,000 in tax, penalties, and interest.
• On behalf of a midwestern restaurant owner, persuaded the IRS Office of Appeals to concede civil fraud penalties and over 90 percent of the adjustments proposed by the IRS’s Examination Division, resulting in a tax savings greater than $600,000.
  Convinced the IRS to reverse a proposed $400,000 adjustment to income resulting from an inaccurately issued Form 1099.