Stuart M. Hurwitz, was recently appointed to the Internal Revenue Service Advisory Council (IRSAC) for a three-year term.
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The IRSAC advises the Commissioner of the IRS on matters relating to the administration of the federal tax system.
PROFESSIONAL EXPERIENCE »
- Member of the Taxation Sections of the State Bar Association of California and the San Diego County Bar Association.
- Past editor of the quarterly newsletter of the Tax Procedure and Litigation Committee of the Taxation Section of the State Bar Association of California.
- Past Chairman of the 3200+ member Taxation Section of the State Bar Association of California.
- Co-leader of the annual Washington trip sponsored by the Taxation Section and the LA County Bar Association Taxation Section at which academic papers are presented to the Internal Revenue Service, U.S. Treasury Department, U.S. Tax Court, and the attorneys for the House and Senate tax writing committees and Joint Committee on Taxation.
- Attendee at previous U.S. Tax Court Judicial Conferences.
- Author of research paper entitled, If the Net Income or Gain Allocated to a Non-Material Partner in a Securities (Trading) Partnership is "Not From a Passive Activity," Then What Is It? Paper was presented on behalf of the Taxation Section of the State Bar of California to officials of the US Department of Treasury and the Internal Revenue Service in May, 1999. It was published in the September, 1999, issue of the California Tax Lawyer and in Tax Notes Today, 1999-TNT 125-41.
- Author of research paper entitled, Valuation and Court-Appointed Experts: Hats Off to the U.S. Tax Court for Using Federal Rule of Evidence §706. Paper was presented on behalf of the Taxation Section of the State Bar of California to attorneys representing the Internal Revenue Service and Judges of the U.S. Tax Court in May, 2001. The article was published in the Winter, 2002 edition of the California Tax Lawyer (Volume 11, Number 2) and the September/October, 2001 issue of Valuation Strategies, a publication of Warren Gorham & Lamont.
- Co-Author of research paper entitled, To What Extent Can an Attorney Participate in the Writing of an Expert's Witness Report in Tax Court. This paper was published in the June, 2004 issue of the Journal of Taxation, a publication of Thomson, RIA.
- Previously served as an Instructor in 'Corporate Taxation' at the University of San Diego School of Business. Served as an Expert Witness for tax and accounting issues.
- Expert in tax audits and tax appeals. Years of primary responsibility for numerous tax audits (primarily field audits) - both state (Franchise Tax Board, State Board of Equalization, Employment Development Department) and federal tax appeals, U.S. Tax Court petitions, Offers-in-Compromise and Installment Agreements, Innocent Spouse Applications, and trust fund penalty and other tax collection issues.
- Supervision of the preparation of thousand's of individual, gift and estate, trust, pension, partnership, and corporate tax returns.
- Provider of legal and tax services to over 800 clients ranging from individual taxpayers, partnerships, trusts and estates, foundations, pension plans, small corporations and limited liability companies, to multi-national corporations. As a result of this involvement, I am familiar with issues of choice and structure of entity, tax treatment of capital gains, deductions, methods of accounting, timing of income, installment sales, sales of corporate assets and corporate stock, independent contractor issues, water's edge elections, tax treaties, pension plan investments and loans, leases, financing and lease treatment of tenant improvements, estate planning, and so forth.
- Owned and operated a real estate development company that developed raw land and constructed residential subdivisions and custom homes in both California and Nebraska.
- Structured business ventures and financing for land and building purchases, construction, and leasehold improvements. Directly involved as either an owner or broker for the purchase, sale, and management and leasing of commercial, industrial, and residential properties. Have been licensed by the State of California as a Real Estate Broker from 1974 to 2002, and licensed as a General Contractor, license type B-1 from 1974 to 1990.
PROFESSIONAL LICENSES »
- State Bar of Nebraska (not renewed).
- State Bar of California. Active Status.
- Certified as a Tax Specialist by the State Bar of California.
MILITARY EXPERIENCE »
- Captain, United States Army Reserve. Active duty - September, 1969, through July, 1971.
- Class Leader, Signal Officers' School; Prosecutor, Signal School Courts and Boards, Fort Gordon, Georgia.
- Contracting Officer, USAHAC, Saigon, Vietnam. Wrote contracts for goods and services for the non-appropriated funds systems (Enlisted, NCO, and Officers' clubs) for the Army, Navy, and Marine Corps. The work involved negotiating and writing contracts with companies and persons from the United States, Vietnam, Thailand, Philippines, Taiwan, Hong Kong, South Korea, Japan, Australia, New Zealand, France, and England.
- Former President of the Jewish Community Centers of San Diego County. Located and spearheaded the land lease for a few dollars a year of 13 acres of real estate owned by the City of San Diego for the construction of the Jewish Community Center in La Jolla, California.
- Formerly coached numerous youth baseball and soccer teams.
- The Ohio State University, B.S. Business Administration, Major in Accounting.
- University of Nebraska School of Law, J.D.
- University of San Diego, LLM (Taxation).