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Tax Court rejects IRS's position that member interests in an LLC are limited partnership interests for passive activity rule purposes under IRC §469.

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Edward I. Kaplan

A member of the Tax group, Ed provides general tax planning counsel and services in the areas of tax controversies, compliance issues, and administrative tax matters before the Internal Revenue Service and Franchise Tax Board. Previously, he was an attorney with the IRS, and spent five years with the San Francisco District Counsel litigating cases and three years as staff attorney to the Deputy Regional Counsel for Tax Litigation (Western Region), overseeing litigation and policy development. Ed currently represents clients in audits and appeals before the IRS and Franchise Tax Board, and in litigation before the Tax Court and the U.S. District Court.



EDUCATION
  • J.D. (with honors), 1981, University of San Francisco School of Law
  • B.A., 1975, University of California, Berkeley

PROFESSIONAL AFFILIATIONS
  • California State Bar, Tax Section
  • Bar Association of San Francisco, Tax Section
  • San Francisco Tax Litigation Club (Past President, 1999)

SPEAKING ENGAGEMENTS
  • “Anatomy of a Tax Controversy,” National Association of Real Estate Companies Annual Conference, May 1995.

Contact
  Tel. 415.981.1400
ekaplan@greeneradovsky.com
Contact
  Tax






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