Finis Cowan, Trial Lawyer - IRS Disputes, Credit Card Defense

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REPRESENTATIVE RECENT ACCOMPLISHMENTS

• Successful audit disputes over for-profit versus hobby status of agricultural and sports promotion activities
• Saved resident alien client from being taxed on annual foreign retirement income based on a tax treaty and statutory exemptions missed by the client’s prior Big 4 CPA firm.
• Secured tax-free treatment of cancellation-of-debt income for clients’ foreign and domestic subsidiaries exchanged to clients’ lenders in debt workout.
  
• Developed tax strategy involving recurring item treatment for clients’ inventory purchase commitment losses, deferring significant taxes when the clients’ cash flow was depressed.
  
• Avoided corporate income tax by converting from C corporations to S corporations, meeting proof requirements and maximizing NOL usage.
• Settled tax malpractice case before filing suit for 50% more than client's authorized sum. Case involved $300K of unsupported purchases deductions and AJEs.

CAREER OVERVIEW AND EDUCATION

• Self employed, 2001 - present
• Mills Shirley LLP -  Litigation Partner, 1991 - 2000.
• Previous experience - Staff accountant

Masters of Tax Law, LL.M. - University of Houston Law Center                                        

Juris Doctorate - Baylor College of Law         

Certified Public Accountant  (retired) - State of Texas       

• 2013 paper on unified business doctrine for "hobby loss" IRS challenges
• July 2012 Update on TSBPA and Innocent Spouse, Houston Chapter TSCPA
• November 2011 Litigation and Divorce Tax Traps, Houston Bar Association
• July 2009 paper, Lifetime GST Tax Exemption Allocation, provides a guide to proper allocation of Generation Skipping Tax Exemptions  
• 2008 LL.M. Thesis: A Tax Policy Analysis of Treatment of Tax Malpractice Recoveries contends that recent IRS rulings are at variance with long-established case law and sound tax policy.
• Accounting Work Papers and Malpractice Prevention, Texas Society of CPA seminars
• Deceptive Trade Practices - Consumer Protection Act Outline, Galveston County Bar Association CLE Seminar

 http://taxproblempros.com/papers_authored_by_finis_cowan