Our attorneys focuses on tax issues for middle-market companies, with a particular focus on tax consequences of Limited Liability Companies (LLCs).
We have previously partnered with Latham & Watkins LLP to file a petition for certiorari seeking Supreme Court review of a decision from the Second Circuit Court of Appeals concerning the tax treatment of employee benefit plans. The petition was based in part on a split in the Circuit Courts concerning the level of review required in appeals from the U.S. Tax Court. Pastore and Latham & Watkins argued that an Article Three District Court should review issues of tax liability for U.S. citizens on a de novo basis, instead of giving deference to the Tax Court, as U.S. citizens are entitled to an Article Three review when issues of their Federal tax obligations are at stake.