Michael Kummer concentrates his practice in the area of tax controversy, with an emphasis on the procedural aspects of tax controversy and litigation. Michael advises sophisticated individual and corporate taxpayers in the real estate, financial services, manufacturing and retail industries. He has substantive experience with issues involving Internal Revenue Code sections 108, 165, 170, 481, 482, Subpart F, Subchapter K, withholding taxes, employment taxes, low-income housing tax credits, and tax incentives for biodiesel and other alternative fuels. Representative successes in which Michael has been involved include obtaining favorable resolutions with the Internal Revenue Service (IRS) regarding valuation challenges and deductions for worthless stock and partnership interests, as well as obtaining a complete concession from the IRS on innocent spouse relief grounds in a pro bono Tax Court representation.
Michael’s practice also involves complex tax planning matters, with an emphasis in the real estate sector. He recently obtained a favorable private letter ruling on a complex issue involving the interplay of the partnership and tax-exempt bond rules.
During law school, Michael clerked at the Commonwealth Attorney’s Office for Kenton County, Kentucky. Under Kentucky’s limited student practice program, Michael second-chaired two jury trials and presented multiple felony cases in preliminary hearings and in grand jury proceedings.