REPRESENTATIVE EXPERIENCE
Shelly has represented domestic and foreign clients before all divisions of IRS and has litigated more than 30 tax cases, some of which include:
- K2 Inc. v. Commissioner, in which the statute of limitations was applicable in a transferee liability case.
- Estate of Williams v. Commissioner, in which the value of interest in the stock of a closely held corporation was at issue, as well as whether the sales proceeds represented a separate asset of the estate or merely replaced an asset that was adeemed (constructively sold before death).
- Carlingswitch v. Commissioner, in which the reasonable compensation of a corporate executive was at issue.
- Ginsburg v. Commissioner, focusing on the proper interplay of various statute of limitations provisions between TEFRA partnership matters and non-TEFRA matters.
- Coggin Automotive Group v. Commissioner, focusing on the business purpose of a transaction and the aggregate versus entity theory for inventory of a partnership.
- Clark Equipment Company v. Commissioner, involving the pooling and costing of inventory items under dollar-value LIFO.
- GEHL Company v. Commissioner, in which the validity of DISC regulation was at issue.
- McNamara v. Commissioner, involving investment tax credit.
PROFESSIONAL HONORS AND AWARDS
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2009, 2010)
- Named to The Best Lawyers in America in the area of tax law (2009, 2010)
- Selected for inclusion in Georgia Super Lawyers® (2010)
- Selected for inclusion in Georgia Super Lawyers®, Corporate Counsel Edition (2009)
PROFESSIONAL AND COMMUNITY INVOLVEMENT
- Board of Directors, Section of Taxation, Atlanta Bar Association
- Member, Association of Former Internal Revenue Executives (AFIRE) (2005–present)
- Board Member, Children’s Community Board, Children’s Healthcare of Atlanta (2005–present)
- Chairman of the Board, Lekotek of Georgia, Inc. (2008–present)
- Board Member, Lekotek of Georgia, Inc. (2005–present)
- Member, Advisory Committee, Low-Income Tax Clinic, Georgia State University Law School (2007–present)
- Fellow, American College of Tax Counsel
RECENT PUBLICATIONS AND SPEAKING ENGAGEMENTS
- Co-author, “Wichita Terminal: An Inference Past Its Time,” Tax Notes (April 13, 2009)
- Co-author, “Using ADR to Resolve Corporate Tax Controversies,” Corporate Business Taxation Monthly (2000)
- Co-author, “Effective Use of Alternative Dispute Resolution Techniques to Resolve Corporate Tax Controversies,” Tax Management Memorandum (1999)
- Author, “Seven Steps to Effective Mediation of Tax Controversies,” Tax Management Special Report (1999)
- Speaker, Tax Education Series VII (April 29, 2009)
- Speaker, “Working with the IRS,” TEI Minnesota Chapter – 26th Annual President’s Seminar, Minneapolis (April 22, 2009)
- Co-speaker, “IRS Hot Topics Impacting Corporate Taxpayers,” TEI Region VII 2008 Conference (July 10, 2008)
- Speaker, “Strategies in Handling Cases Before the U.S. Tax Court,” National Teleconference/Webcast, Lorman Education Services (February 7, 2008)
- Panel Member, “Tax Accrual Workpapers,” KPMG Seminar (December 3-5, 2007)
- Panel Member, “Strategies in Handling Federal Tax Controversies,” Sutherland Tax Education Series (November 5, 2007)
- Speaker, “Dealing with the IRS – Current Controversies and Procedures,” TEI Region VII 2007 Conference (July 12, 2007)
- Co-speaker, “Current IRS Controversy News,” TEI Region II 2007 Conference (June 1–6, 2007)
- Speaker, “Tax Accounting Methods,” Sutherland Education Series (May 2007)
- Panel Member, “LMSB – Tension Between Audit and Appeals,” TEI Atlanta Chapter – PricewaterhouseCoopers 2007 Seminar (April 28, 2007)
- Co-speaker, “FIN 48: “Reportable Transactions,” Sutherland Tax Education Series (April 24, 2007)
- Speaker, “Rules of Engagement with Today’s IRS,” TEI Atlanta Chapter – Grant Thornton 2007 Seminar (February 20, 2007)