Evan advises RSM clients on a variety of issues to include: IRS examination and IRS appeals matters, penalty and interest abatements, 9100 relief for missed elections, refund and informal refund claims, entity issues (entity classification election and late entity classification elections, EIN retention after merger), international tax controversy issues (e.g. Delinquent International Information Return Submission Procedures, Section 965 issues, and FBAR Delinquent Submission Procedures), IRS filing issues. He also assists clients with IRS account issues and advises on IRS Collection procedures (lien, levy, collection due process hearings).
Prior to joining RSM, Evan was an Assistant Deputy Counsel at the United States Tax Court where he resolved routine and complex procedural motions in the Court’s general docket, advised Judges on procedural and substantive tax matters, and handled procedural inquiries from petitioners and practitioners. Prior to joining the Court, Evan was an attorney with the IRS Office of Chief Counsel National Office, Procedure and Administration. While there, he was a subject-matter expert in post assessment tax controversy and litigation. He provided technical advice to field attorneys concerning assessments, liens, levies, collection due process, Tax Court, and federal court appellate litigation. He further provided advice pertaining to restitution, overpayments, credit and refund litigation, trust fund recovery penalties, deficiency notices, abatement, methods of collection, collection statutes of limitation, and ex- parte communication.
Evan is also a military veteran who served 22 years as an active duty Army Judge Advocate. He served as the Director of the Armed Forces Tax Council and Tax Advisor to the Office of the Secretary of Defense for his final assignment. He provided tax advice to the Secretary and the departments on a wide range of tax issues relating to services members, compensation policies, employment tax, treaties, tax exempt entities, and excise taxes.