Professional Experience

Morrison Law Firm, PLLC — Helena, Montana

Attorney | 2018 – Present

Sophisticated and selective practice focused on criminal and civil tax controversies, audit defense, regulatory and internal investigations, and appeals. Regularly represents clients in federal and state courts, IRS and state tax disputes, and investigations by federal and state agencies—including the IRS Criminal Investigation Division. Frequently collaborates with law and accounting firms nationwide on high-profile tax matters.

Experience spans all phases of litigation: investigations, audits, discovery, motions practice, witness preparation and examination, and trials. Advises nonprofit organizations, captive insurance companies, and taxpayers on complex compliance issues.

Representative Matters

• Lead counsel in damages hearing in a $9 million tax promoter case before the District Court of Montana; presented oral argument before the Ninth Circuit Court of Appeals.
• Lead counsel in constitutional challenge to Montana’s net operating loss computation for nonresidents—argued before the State Tax Appeal Board, First Judicial District Court, and Montana Supreme Court.
• Successfully argued before the Montana Supreme Court for reversal of the Attorney General’s legal sufficiency opinion on an election ballot measure.
• Lead counsel in successful challenge to interest charged on pass-through withholding for non-resident owners in state district court.
• Obtained pre-trial diversion for a client facing a five-count indictment (bank fraud, wire fraud, false statements).
• Secured a $3 million class-action settlement in a case alleging wrongful withholding by the State of Montana.
• Lead counsel in successful federal tax refund claim concerning taxation of duty-based disability benefits in federal district court.
• Authored and successfully lobbied for passage of a mobile home tax exemption in Montana.
• Served as expert witness on nonprofit taxation in a successful criminal defense of an elected official.
• Successfully defended a client in a hobby-loss case before the State Tax Appeal Board.

Miller & Chevalier — Washington, D.C.

Attorney | 2015 – 2018

Practice focused on tax controversies, tax policy, and sophisticated transactional tax advice. Researched and assisted in drafting motions and trial briefs; attended trials and hearings in the U.S. Tax Court and D.C. District Court. Prepared witnesses for trial—including economic experts from Yale University and corporate executives. Experienced with legal research and e-discovery platforms.

Representative Matters

• Represented The Coca-Cola Company in multi-billion-dollar transfer pricing litigation, including a six-week trial in U.S. Tax Court.
• Represented Starr International Company in refund litigation over denial of U.S.-Swiss treaty benefits.
• Drafted and obtained IRS private letter rulings for international energy companies, including on tax attributes related to decommissioning nuclear power plants.
• Assisted firm lobbyists in tracking and advising clients on potential impacts of new tax legislation.
• Authored and successfully lobbied for a D.C. tax exemption for a local homeless shelter.
• Served as registered lobbyist for a national marketing cooperative.

United States Senate Committee on Finance — Washington, D.C.

Staff / Research Assistant on Tax Policy | 2009 – 2012

• Began as Senate Staff to U.S. Senator Max Baucus; promoted to Research Assistant on Tax Policy.
• Supported Tax Counsel by drafting policy proposals, evaluating fiscal impacts of legislation, organizing tax-related hearings, and preparing talking points for Chairman Baucus.
• Provided key support during federal deficit negotiations, payroll tax cut extensions, and Highway Trust Fund reauthorization.
• Developed deep expertise in federal tax legislation and policy development.

Education

• Harvard Law School, Cambridge, MA
  J.D., Cum Laude | June 2015
  • Congress Editor, Harvard Journal on Legislation
  • Intern, International Tax Department, VMware, Inc.
• Davidson Honors College, University of Montana, Missoula, MT
  B.A. in Economics and English, High Honors | May 2009
  • University Scholar
  • President’s Outstanding Senior Recognition Award (Economics)
  • Department of Economics Award for Best Senior Thesis

Publications

• “A Big Return to Reasonable Compensation,” Tax Notes, Vol. 163.13 (June 24, 2019)
• “The IRS and America’s Longest Running ADR Program,” The Federal Lawyer, Vol. 63.9 (Oct/Nov 2016)
• “Treasury and IRS Tighten Anti-Inversion Rules in Latest Round of Guidance But Take No Action on Earnings Stripping,” Miller & Chevalier International Tax Alert (November 24, 2015)
• “Public Trust or Equal Footing: A Historical Look at Public Use Rights in American Waters,” Hastings Environmental Law Journal, Vol. 21.1 (Winter 2015)

Speaking Engagements

• “Congress on the Case: An Inside Look at Congressional Tax Investigations,” ABA Fall Tax Conference, Dallas, TX (2022)
• “International Tax Reform,” Miller & Chevalier Tax Reform Webinar Series (2017)
• “Tax Legislative Update: Tax Reform on the Horizon?,” Tax Executives Institute, Dallas, TX (2017)
• “Tax Legislation: What’s on Deck for this Congress and Administration,” ABA Young Tax Lawyers Symposium, Washington, D.C. (2017)
• Multiple “Tax Legislative Update” presentations for Corporate Executive Board, Tax Leadership Council (2016–2017)

Professional Associations

• Member, Section of Taxation, American Bar Association
  • Co-Chair, Legislative and Administrative Developments Committee (Current)
  • Co-Chair, Criminal and Civil Tax Penalties Subcommittee (2022–2023)
• Member, TEGE Exempt Organizations Council
• Member, BETTR Section, Montana State Bar Association

Bar Admissions

• Montana
• District of Columbia (inactive)
• U.S. District Court for the District of Montana
• U.S. Court of Appeals for the Ninth Circuit
• United States Tax Court

Community Involvement

• Vice Chair, University of Montana Alumni Association
• Director, Montana Legal Services Association
• Coach, Helena High School Mock Trial Team