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Mr. Stark focuses on federal income tax matters. He has extensive experience in tax controversy matters, including audits, appeals and litigation.
Representative cases in which Mr. Stark was either counsel of record or a principal participant include the following:
The Dow Chemical Company v. United States, 250 F. Supp. 2d 748, modified by 278 F. Supp. 2d 844 (E.D. Mich 2003) (on appeal)
GlaxoSmithKline Holdings Inc. v. Commissioner, 117 T.C. 1 (2001) (perpetuation of testimony in transfer-pricing dispute)
American States Insurance Co. v. Bower, Dkt 01-L-50940 (Ill. App., appeal pending) (characterization of § 338 (h) (10) gain as nonbusiness income)
Peerless Industries v. United States, 94-1 USTC 50,043 (E.D. Pa.), aff’d per curiam, 37 F.3d 1488 (3d Cir. 1994) (business purpose doctrine)
Mobil Exploration & Producing North America, Inc. v. United States, 27 Fed. Cl. 463 (1993) (windfall profit tax)
Woods Investment Co. v. Commissioner, 85 T.C. 274 (1985), acq. 1986-2 C.B. 1 (consolidated returns)
Mr. Stark began his career in private practice in Dallas, Texas in 1976, where he practiced for ten years. From 1986 to 1989, he served as assistant to the commissioner of the Internal Revenue Service. He is a past chair of the Taxation Section of the District of Columbia Bar Association and of the ABA Section of Taxation’s Administrative Practice Committee. He is also a fellow of the American College of Tax Counsel.
Mr. Stark served as Special Projects Editor for the Vanderbilt Law Review. He is a member of the Order of the Coif and Phi Beta Kappa. | 