| George Hani concentrates his practice on the resolution of tax controversies at the administrative level. He has represented clients in traditional Internal Revenue Service (IRS) examinations and administrative appeals, as well as in connection with a number of IRS dispute resolution programs, such as the Pre-Filing Agreement (PFA) program, the Compliance Assurance Process (CAP), Fast Track Appeals, and Accelerated Issue Resolution (AIR). Mr. Hani has assisted taxpayers to secure private letter rulings and favorable technical advice memos from the IRS National Office. When necessary, he has represented taxpayers in United States Tax Court and the United States Court of Federal Claims. He has also represented individuals in collection matters and criminal investigations. More > George Hani concentrates his practice on the resolution of tax controversies at the administrative level. He has represented clients in traditional Internal Revenue Service (IRS) examinations and administrative appeals, as well as in connection with a number of IRS dispute resolution programs, such as the Pre-Filing Agreement (PFA) program, the Compliance Assurance Process (CAP), Fast Track Appeals, and Accelerated Issue Resolution (AIR). Mr. Hani has assisted taxpayers to secure private letter rulings and favorable technical advice memos from the IRS National Office. When necessary, he has represented taxpayers in United States Tax Court and the United States Court of Federal Claims. He has also represented individuals in collection matters and criminal investigations.
Mr. Hani has broad, substantive experience in areas including worker classification, employee fringe benefits, Section 475 mark-to-market issues, and U.S. withholding taxes. He has significant background in issues related to purchase price allocation and valuation for such items as standing timber, mining property, covenants not to compete, and professional sports player contracts. He also has extensive experience defending against IRS challenges to the use of various tax incentives, such as the credits for making solid synthetic fuel from coal and for enhanced oil recovery (EOR), the allowance of accelerated depreciation for property placed in service on an Indian reservation, and the use of tax-exempt financing to construct recycling facilities.
He is a frequent speaker at Tax Executives Institute (TEI) chapter meetings and programs and has published several articles in TEI’s The Tax Executive. While attending the Catholic University of America Columbus School of Law, Mr. Hani was a member of the Catholic University Law Review. < Brief Bio
- Schedule UTP Comments. On behalf of a coalition of companies, submitted comments to the Internal Revenue Service regarding the draft schedule and instructions for certain taxpayers to identify all of their "uncertain tax positions" as part of their tax returns. Many of our recommendations, which focused on how the schedule and instructions could be modified to be less burdensome to taxpayers, were adopted in the final schedule and instructions (as explained in Announcement 2010-75).
Government Experience
- Honors Attorney, U.S. Department of the Treasury, 1995 - 1996
- Honors Attorney, Office of the Associate Chief Counsel (International), Internal Revenue Service, 1994 - 1995
Professional and Community Involvement
- Chair, Tax Audits and Litigation Committee, Taxation Section, District of Columbia Bar
Bar Admissions - District of Columbia
- Maryland
Court Admissions - United States Tax Court
- United States Court of Federal Claims
Education - J.D., The Catholic University of America, Columbus School of Law, magna cum laude, 1994
- Ed.M., Harvard University, 1991
- B.A., Duke University, 1987
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