David is the practice group leader of the Utility Tax Practice Group. While David advises a diverse client group on a wide range of federal income tax matters, the bulk of his practice consists of representing utility industry clients. He addresses Internal Revenue Service audit and appeals issues, secures private letter ruling, technical advice memoranda and permission to change methods of accounting from the national office of the Internal Revenue Service and participates in tax litigation, tax planning and the structuring and evaluation of proposed transactions. He provides tax return review services to a large number of utility clients advising these companies regarding the appropriate positions to be reflected on income tax returns. David has served as an expert witness on tax matters in utility rate cases.

In addition, David represents clients with respect to legislative and tax policy matters emanating from Capitol Hill, the Internal Revenue Service and the Department of Treasury. His knowledge and facility in this area is, at least in part, a function of his prior experience as tax counsel to the Senate Finance Committee and as attorney advisor in the office of chief counsel of the Internal Revenue Service.

Representative Experience
Has represented numerous clients before the IRS and the Department of Treasury and advised client with respect to tax policy issues, regulatory interpretative issues, tax audits and appeals, private letter rulings and changes in methods of accounting.

Representative issues include:

• Normalization
• Deductibility of Repairs
• Tax Credits
• Placed in Service for Power Plants and other Facilities
• Depreciation of Power Plants and other Facilities
• Casualty Losses
• Renewable Energy Certificates (RECs)
• Domestic Production Deduction
• Treatment of Nuclear Licenses and other Intangible Assets
• Penalties

Publications
"Casualty Repairs Under the Proposed Capitalization Regs", Tax Notes, Volume 120, Number 10, September 8, 2008, pg. 961.