Board Certified in Tax Law by the Texas Board of Legal Specialization, David defends businesses and individuals facing tax problems that not only trigger a potentially higher tax bill but also a criminal investigation or prosecution. Regardless of whether a case involves allegations of tax evasion, failure to file, or a fraudulent return, he focuses on finding a solution during the investigation stage before an indictment is issued. Resolving criminal matters at this early stage is critical because an indictment significantly increases the likelihood of a conviction at trial, which may result in considerable penalties or even jail time.

In civil matters, David explores every option available to prevent unanticipated tax liabilities from devastating a client’s business, either by resolving the controversy during the IRS audit process or in litigation before the U.S. Tax Court, U.S. Court of Federal Claims, or the federal district and bankruptcy courts. He also has deep experience in resolving administrative controversies before state and local tax authorities, including disputes involving income tax, sales/use tax, and franchise tax.

David has handled several recent IRS controversies, including energy efficiency credits and deductions, tax shelter liability, and collection cases targeting nominees and fraudulent transfers. He also helps clients decipher the recently enacted U.S. Tax Code provisions, with a particular emphasis on the new rules governing partnership audits.

In addition to his controversy practice, David helps businesses and entrepreneurs develop proactive tax and estate planning strategies to avoid future disputes and minimize taxes, including income, estate, gift, GST, franchise, and sales/use tax.

IRS, State Civil, and Criminal Tax Litigation/Controversy Work

• Caused the IRS to withdraw a wrongfully filed nominee tax lien in the amount of approximately $1.5 billion.
• Represented a lighting systems company in an appeal involving a multimillion-dollar tax deduction under IRC Section 179D.
• Assisted a client who fell victim to tax shelter promoters in getting negligence and fraud penalties abated in full.
• Obtained full innocent spouse relief for a single mother of two.
• Represented a construction company in an IRS dispute over worker classification and achieved a $4.4 million reduction in liability.
• Represented an online marketing service provider in a tax litigation case and received a complete concession from the comptroller that zero was owed.
• Representation of clients in IRS criminal matters and voluntary disclosures.
• Representation of clients in pre-indictment investigations resulting in no indictments being filed.
• Represented a Certified Public Accountant in a half-million-dollar IRS trust fund recovery case.
• Represented tax professionals in criminal tax matters, including a jury trial resulting in 12 not-guilty verdicts.
• Obtained a 100% abatement of a multimillion-dollar IRS jeopardy assessment.
• Obtained a reversal of a wrongful income tax assessment and wage levy relief.
• Handled IRS audits of various corporations and individuals.
• Representation of clients with state tax issues, including property taxes and sales and use taxes.
• Obtained double taxation relief for clients through IRS private letter ruling requests.
• Represented clients in estate and gift tax valuation matters.
• Filed and obtained relief of tax liabilities through offers in compromise and other administrative remedies with the IRS and state taxation authorities.
• Obtained significant tax refunds for clients through refund actions both administratively and through U.S. district court and the Court of Federal Claims actions.
• Representation of Certified Public Accountants before the IRS Office of Professional Responsibility, malpractice litigation, and the Board of Accountancy.

Estate Planning, Probate, and Transactional Work

• Counseling clients on all phases of estate planning and preparing wills and various forms of trusts to affect property transfer goals and minimize estate and gift taxes.
• Design and implement multiple family limited partnerships, family limited liability companies, and trusts for family-owned assets.
• Representing clients in numerous will probates and in the administration of the estate.
• Provide corporate and partnership tax planning for entrepreneurial business owners.
• Structuring and documenting sales and purchases of business entities and business properties.
• Provide counseling and planning for troubled businesses and entrepreneurs.
• Creating business entities such as corporations, limited liability companies, and professional associations.
• Prepared tax opinions on various matters, including 1031 Exchanges, Prohibited Transactions for IRAs, and listed transactions.

• Lawdragon 500 Leading Global Tax Lawyers Guide, Tax Controversy, Litigation, High Net Worth (2025)
• Fellow, American College of Tax Counsel
• The Best Lawyers in America®, Litigation and Controversy – Tax, Tax Law (2016-2026)
• D Magazine, Best Lawyers in Dallas, Tax Litigation (2014, 2018-2025)
• Super Lawyers® Top 100 Lawyer in Texas, Tax Law (2018-2020, 2024)
• Super Lawyers® Texas, Tax Law (2014-2021, 2024)
• Super Lawyers® Texas Rising Star, Tax Law (2010-2013)
• The Cardozo Society of the Jewish Federation of Greater Dallas, Outstanding Attorney Under 40 (2014)