Represents companies and individuals in complex, high-stakes Federal tax controversies.
Defends individuals in tax fraud prosecutions.
Brings U.S. citizens and residents into compliance with U.S. laws concerning foreign income, accounts, and entities, and defends them against penalties for alleged noncompliance.
Advises U.S. citizens and lawful permanent residents on expatriation from the U.S. and, when it is in their best interests, helps them expatriate.
Does not seek honors or awards. Prefers to let his work speak for itself. These recognitions, however, are significant
B.S.B.A., cum laude, Accounting, Aquinas College (1978).
J.D., Notre Dame Law School (1985). Staff Member and Associate Editor, Notre Dame Law Review.
LL.M. (Taxation), Washington University in St. Louis Law School (1991).
State Bar of Michigan (1985)
United States Supreme Court (1999)
United States Court of Appeals for the Sixth Circuit (1986)
United States Court of Appeals for the Eighth Circuit (1988)
United States Court of Appeals for the Third Circuit (2020)
United States Court of Appeals for the Federal Circuit (1988)
United States District Court for the Western District of Michigan (1985)
United States District Court for the Eastern District of Michigan (1996)
United States District Court for the Eastern District of Missouri (1988)
United States Court of Federal Claims (1988)
United States Tax Court (1986)
Certified Public Accountant, Michigan (1980)
“Abdo, Kwong, and the List of Disregarded Acts of IRC § 7508A(d)(1),” Tax Notes Federal, June 18, 2026.
“Due Process in Federal Tax Assessments,” Tax Notes Federal, April 6, 2026.
“Due Process of Law and International Information Return Penalties,” LACHES, Oakland County Bar Association, April, 2026.
“Penalty Relief for Doctors Victimized by Foreign Trust Schemes,” Tax Notes Federal and Tax Notes International, and ABA RPTE eReport, October, 2024.
“Written, Supervisory Approval of Penalties Required Under Section 6751(b),” Tax Notes Federal and Tax Notes International, and ABA RPTE eReport, April, 2024.
“Forms 8938, 5471, 3520, 3520-A, 5472, 8865, and 926 and Assessable v. Nonassessable Penalties,” Tax Notes Federal and Tax Notes International, July, 2023.
“U.S. Income Taxation of U.K.-Based Pension Plans,” Tax Notes Federal and Tax Notes International, March, 2023.
On May 9, 2026, shared a panel on “Due Process at 250: Penalties, Parallel Proceedings, and Constitutional Limits” at American Bar Association, Taxation Section Annual Meeting in Washington, D.C.
Chair, moderator, speaker, ABA, Tax Section, CCTP webinar, “Navigating the Minefield of international Information Returns: Compliance and Controversy,” January, 2026.
Served as chair and moderator of group that presented “Expatriation From the United States” at the ABA, RPTE National CLE Conference in Las Vegas, Nevada in May, 2025. The presentation was well-attended, and we received several insightful questions.
In February, 2025, co-presented “International Information Return Penalties Update” to RPTE Income and Transfer Tax Planning Group, 2025, and presented it to Oakland County Bar Association Tax Committee.
In December, 2024, served as moderator and speaker for RPTE eCLE webinar, “International Information Return Penalties: Compliance and Controversy.”
In May, 2024, co-presented “International Information Return Penalties” at the Annual Tax Institute co-sponsored by the Institute of Continuing Legal Education and the State Bar of Michigan, Taxation Section.
In March, 2024, served as leader and co-presenter of “Internal Revenue Code Section 6751(b)(1)” in a monthly Zoom call for RPTE Income and Transfer Tax Planning Group.
In January, 2024, co-presented “Introduction to Practice Before the IRS” at the State Bar of Michigan, Taxation Section, Fundamental Skills Program.
Co-Chair, Subcommittee on International Tax Enforcement, Committee on Civil and Criminal Tax Penalties, Taxation Section, ABA, 2025-present.
Vice Chair, International Tax Planning Committee, Section of Real Property, Trust and Estate Law, ABA, 2023-2025.
Chair, Federal Tax Committee, Taxation Section, State Bar of Michigan, 2023-2025.
Together with wife, Geri L. Dunn, has three children and 15 grandchildren. Loves Notre Dame football, the Detroit Tigers, the Detroit Lions, and the Detroit Red Wings. Runs and works our regularly. Frequent blood donor.
Leads team that ministers weekly at a Medicaid nursing home in Oakland County, Michigan. Serves on Bishop’s Dinner Committee of Guest House, Lake Orion, Michigan, and on Finance Committee of Loyola High School, Detroit, Michigan.
Does not seek honors or awards. Prefers to let his work speak for itself. These recognitions, however, are significant:
B.S.B.A., cum laude, Accounting, Aquinas College (1978).
J.D., Notre Dame Law School (1985). Staff Member and Associate Editor, Notre Dame Law Review.
LL.M. (Taxation), Washington University in St. Louis Law School (1991).
State Bar of Michigan (1985)
United States Supreme Court (1999)
United States Court of Appeals for the Sixth Circuit (1986)
United States Court of Appeals for the Eighth Circuit (1988)
United States Court of Appeals for the Third Circuit (2020)
United States Court of Appeals for the Federal Circuit (1988)
United States District Court for the Western District of Michigan (1985)
United States District Court for the Eastern District of Michigan (1996)
United States District Court for the Eastern District of Missouri (1988)
United States Court of Federal Claims (1988)
United States Tax Court (1986)
Certified Public Accountant, Michigan (1980)
“Abdo, Kwong, and the List of Disregarded Acts of IRC § 7508A(d)(1),” Tax Notes Federal, June 18, 2026.
“Due Process in Federal Tax Assessments,” Tax Notes Federal, April 6, 2026.
“Due Process of Law and International Information Return Penalties,” LACHES, Oakland County Bar Association, April, 2026.
“Penalty Relief for Doctors Victimized by Foreign Trust Schemes,” Tax Notes Federal and Tax Notes International, and ABA RPTE eReport, October, 2024.
“Written, Supervisory Approval of Penalties Required Under Section 6751(b),” Tax Notes Federal and Tax Notes International, and ABA RPTE eReport, April, 2024.
“Forms 8938, 5471, 3520, 3520-A, 5472, 8865, and 926 and Assessable v. Nonassessable Penalties,” Tax Notes Federal and Tax Notes International, July, 2023.
“U.S. Income Taxation of U.K.-Based Pension Plans,” Tax Notes Federal and Tax Notes International, March, 2023.
On May 9, 2026, shared a panel on “Due Process at 250: Penalties, Parallel Proceedings, and Constitutional Limits” at American Bar Association, Taxation Section Annual Meeting in Washington, D.C.
Chair, moderator, speaker, ABA, Tax Section, CCTP webinar, “Navigating the Minefield of international Information Returns: Compliance and Controversy,” January, 2026.
Served as chair and moderator of group that presented “Expatriation From the United States” at the ABA, RPTE National CLE Conference in Las Vegas, Nevada in May, 2025. The presentation was well-attended, and we received several insightful questions.
In February, 2025, co-presented “International Information Return Penalties Update” to RPTE Income and Transfer Tax Planning Group, 2025, and presented it to Oakland County Bar Association Tax Committee.
In December, 2024, served as moderator and speaker for RPTE eCLE webinar, “International Information Return Penalties: Compliance and Controversy.”
In May, 2024, co-presented “International Information Return Penalties” at the Annual Tax Institute co-sponsored by the Institute of Continuing Legal Education and the State Bar of Michigan, Taxation Section.
In March, 2024, served as leader and co-presenter of “Internal Revenue Code Section 6751(b)(1)” in a monthly Zoom call for RPTE Income and Transfer Tax Planning Group.
In January, 2024, co-presented “Introduction to Practice Before the IRS” at the State Bar of Michigan, Taxation Section, Fundamental Skills Program.
Co-Chair, Subcommittee on International Tax Enforcement, Committee on Civil and Criminal Tax Penalties, Taxation Section, ABA, 2025-present.
Vice Chair, International Tax Planning Committee, Section of Real Property, Trust and Estate Law, ABA, 2023-2025.
Chair, Federal Tax Committee, Taxation Section, State Bar of Michigan, 2023-2025.
Together with wife, Geri L. Dunn, has three children and 15 grandchildren. Loves Notre Dame football, the Detroit Tigers, the Detroit Lions, and the Detroit Red Wings. Runs and works our regularly. Frequent blood donor.
Leads team that ministers weekly at a Medicaid nursing home in Oakland County, Michigan. Serves on Bishop’s Dinner Committee of Guest House, Lake Orion, Michigan, and on Finance Committee of Loyola High School, Detroit, Michigan.
