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Linda S. Paine has represented hundreds of clients with tax disputes before the Internal Revenue Service or the Texas Comptroller’s Office, amassing a record of considerable success through settlement or litigation. Her experience includes handling disputes in which at issue were amounts ranging from tens of thousands of dollars to tens of millions. Her practice involves a wide range of tax issues including excise, income and estate and gift tax disputes. Ms. Paine is a former Senior Tax Attorney and Director of The Tax Legal Group for Tenneco, Inc., where she worked on tax opinions relating to mergers, acquisitions and divestitures; handled all state and federal tax appeals and litigation; and provided opinions on reporting positions and tax planning.Significant Cases Jade Trading, LLC v. United States, Fed. Cl. No. 03-2164T (whether purchased option and sold option are separate or single and whether penalties might apply) Santa Monica Pictures, LLC v. Commissioner, T.C.M. 2005-104 (contribution of subsidiary with distressed debt not recognized) Horton Homes, Inc. v. United States, 357 F.3d 1209 (11th Cir. 2004) (excise tax regulations invalidated) AmSouth Bank v. Commissioner, (settled valuation issues after trial for refund) CMA Consolidated, Inc. v. Commissioner, T.C.M. 2000-16 (deductions relating to equipment "lease strip" disallowed for lack of business purpose) Henry Randolph Consulting v. Commissioner, 133, T.C. 250 (1999) Foretravel, Inc. v. Commissioner, 70 T.C.M. (CCH) 1007 (1995) (bad debt deduction relating to wholly owned subsidiaries sustained) Central deChihauhua v. Commissioner, 102 T.C. 515 (1994) Powers v. Commissioner, 100 T.C. 457 (1993) O'Daniel v. United States, 6 F.3d 321 (5th Cir. 1993) (transfer of life insurance policies on insurance company forms within three years of death not included in estate because operative date of transfer when life insurance trust created) H Graphics/Access, Ltd. v. Commissioner, 63 T.C.M. (CCH) 3148 (1992) (no fraud involved in executing settlement agreement) Metro-National Corp. v. Commissioner, 52 T.C.M. (CCH) 1440 (1987) (investment credit allowed on moveable partitions and other property) Presentations Square Corners and Curves: Throw Your Professional Compass Away. You Need a GPS System to Navigate Now!42nd Annual Southern Federal Tax Institute-October 2007, Atlanta, Georgia2007 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas2008 C.P.E. Tax Expo, TSCPA Foundation - Houston, Texas News from the Front: Taxpayer Wins and Losses in the Privilege Wars.2005 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas Estate and Gift Tax Audits: How to Handle Them and How to Avoid Them.2004 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas Overview Of The 2004 Filing Season: Protecting Your Clients And Yourself From IRS PenaltiesChamberlain Hrdlicka January 2004 Tax Forum - Houston, Texas The Marriage Trap: Escaping Your Spouse's Tax Liability Attorneys in Tax and Probate - January 2004 - Houston, Texas Scams, Shams & Shelters - What's a CPA to Do?C.P.E. Tax Expo, Houston TSCPA Foundation - January 2004, Houston, TexasHouston TSCPA Foundation - June 2003 - Houston, TexasBKD, LLP - September 2003 - Houston, Texas The Federal Tax Return Preparer's Privilege-Cloak or Fig Leaf?2003 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas Hardball! Will Legitimate Tax Planning Be Struck Out? 2002 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas When Your Client Can't Pay. IRS Collection Alternatives 2002 Chamberlain Hrdlicka Annual Tax Planning Seminar - Atlanta, Georgia There's No Education in the Second Kick of a Mule CBIZ 2001 Annual Seminar - Dallas, Texas Abatement of Interest - Fact or Fantasy?2000 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas What CPA’s Need to Know About Taxation of Intellectual Property Choice of Entity and Acquisition Issues - 1997 Woodlands Area Tax Forum, Houston, Texas Taxpayers’ Bill of Rights II - This Time It’s Real - 1996 Chamberlain Hrdlicka Tax Forum - Houston, Texas Proprietorship, L.L.C., Partnership or Corporation: Choosing the Right Entity in Light of The New Check-in-the Box Regulations - 1996 Chamberlain Hrdlicka Tax Forum - Houston, Texas Marriage, Divorce and Taxes: Protecting Spouses From the IRS and Each Other - 1996 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas Can a Person Serve Two Masters? Employee Leasing Presents a Devilish Dilemma - 1995 Houston, Texas Recent Developments in IRS Collection Procedures and Tax Dischargeability in Bankruptcy - 1995 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas Sales & Employment Taxes - A Thorn in the Side of Landscape Contractors - 1994 - Texas Association of Landscape Contractors - Houston, Texas Negotiating at Appeals: A Fresh Look at Conventional Methods and Wisdom - 1994 C.P.E. Tax EXPO, TSCPA Foundation - Houston, Texas Traps for the Unwary: Steering Clients Clear of State Tax Pitfalls - 1994 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas - CPA Society, Victoria, Texas The Latest Endangered Species: The Vanishing American Independent Contractor - 1994 CPA Society, Victoria, Texas On the Front Burner: Hot Issues in State and Local Taxation - 1993 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas IRS Audits of Multinational Activities - A New Breed of International Intrigue - Presented in Brownsville and McAllen, Texas, 1993 Strategies for Settling or Litigating Continuing Issues - 1993 General Motors Tax Conference On the Front Burner: Hot Issues in State Taxation of Interstate Commerce - 1992 Chamberlain Hrdlicka Annual Tax Planning Seminar - Houston, Texas Penalties: The Not So Secret Weapon - 1993 Large Case Audit - Atlanta, Georgia, Houston, Texas Flag on the Play - Taking the Penalty or Demanding Review - 1993 - Houston, Texas Estate Tax Audits and Litigation: When Your Most Careful Plans Go Awry - 1993 Wills and Probate Institute - Houston, Texas Large Case Audit and Appeals - Edison Electric Seminar - 1990 - Denver, Colorado Large Case Initiative: The IRS Takes Aim at the 100 lb. Gorilla - 1990 - Atlanta, Georgia Doing Business with the New Comptroller-A Sharp Look at the New Franchise Tax in Texas - 1990 - Houston, Texas Penalties: The Impact on Negotiation and Litigation - 1989 - Houston, Texas Articles & Publications Deadline for IRS Voluntary Compliance Initiative, Banking and Finance column, Houston Business Journal, March 7, 2003 Bankruptcy: Blessing or Curse, Taxing Matters column, DBAHouston, July 1995 Professional AffiliationsAmerican Bar Association, Tax Section State Bar of Texas, Tax Section Houston Bar Association, Tax Section Martindale-Hubbell rating - AV. |
