C. Ted Sanderson Jr.

Regularly represents individuals and businesses in tax controversies with the Internal Revenue Service (IRS) or Mississippi Department of Revenue (MDOR) in audit, administrative appeal, collection, and litigation, achieving significant reduction of tax/penalties/interest that had been asserted by the taxing authority and, in many instances, a tax refund for the client.

Represented clients in the home health care industry in unprecedented $1 million attorney fees award against the IRS.

Obtained more than $10 million of sales and severance tax refunds from MDOR on claims for refund filed on behalf of clients in the oil and gas and home health care industries.

Recently obtained a complete concession by IRS in a $1.8 million gift tax deficiency in United State Tax Court without a trial.

Represented multiple clients in obtaining favorable Private Letter Rulings (PLRs), Technical Advices, and other rulings from the IRS, notably PLRs on tax-free corporate "spin offs" under IRC § 355 including a nationally significant ruling for a manufacturing client where the IRS approved "liability protection" as a valid "business purpose" for the transaction under § 355.

Regularly participates in legislative and regulatory processes at federal and state levels on tax matters of importance to clients including (i) participated in comment and hearing process before the IRS on proposed regulations that would have been adverse to an estate client resulting in the withdrawal of the proposed regulations by the IRS, and (ii) secured clarification amendments to a state sales tax statute to stop MDOR's unfavorable application of the statute to clients in the home health care business.

Assisted various owners of closely held businesses (retail, manufacturing, home health, oil & gas, farming/timber, etc.) on the transfer of business interest to successive generations, including by gifts and sales to trusts, removing millions of dollars of value and future appreciation from the transferors' estates without any transfer tax.

Regularly assists business owners with asset protection and business succession planning including devising buy-sell arrangements among the owners to avoid or deal with disputes and to provide for orderly succession of the business, negotiating and preparing pre-nuptial agreements, and advising high net worth (HNW) clients in divorce proceedings on strategies to protect "separate/non-marital property" and on the financial and tax aspects of divorces.

Advised large estates and trusts on post-mortem tax planning resulting in significant reduction of tax that would have been owed due to lack of proper pre-death planning and/or inadequate initial post-death tax reporting, including refunds of tax and abatement of penalties.

Advises companies and real estate investors/developers on utilization of tax incentives and unique financing alternatives such as tax incremental financing (TIFs), special assessments, and property tax exemptions, and in seeking public funds for projects from local, state and federal governments.

Handled numerous "like-kind exchanges" of real estate for individual clients and trust departments acting as "qualified intermediaries," including complex transactions involving multiple parties and properties, real estate owned by partnerships or tenants in common (TICs), and "reverse exchanges."

Regularly advises real estate investors/developers in structuring joint ventures and on strategies to minimize tax.

Represented multiple clients in acquisitions and sales of businesses ranging in size from a few hundred thousand dollars to more than $100 million, including sales of stock to employee stock ownership plans (ESOPs).