Carmen J. SantaMaria

Tax Controversies

Estate of Rutherford P. Boyd – 2011

Successfully settled the federal estate tax litigation initiated by the estate of the second generation owner of Boyd Coffee Co. involving the value of the decedent’s stock in such privately owned company.

Estate of Alan James – 2010

Successfully settled the federal estate tax litigation initiated by the estate of one of the founding shareholders of The Greenbrier Companies, Inc. involving, among other issues, the value of the decedent’s stock in such publicly traded company.

IRS Audit – 2008

Successfully resolved the IRS audit of a senior executive of a large nonprofit corporation, resulting in the IRS abandonment of all intermediate sanctions penalties.

Private Letter Ruling – 2007

Obtained a favorable IRS private letter ruling for the manufacturer of specialty “live-floor” trailers that the bodies of such trailers are exempt from federal excise tax.

University Surgical Associates – 2003

Successfully settled the federal income tax litigation initiated by one of 14 TEFRA partnerships, historically used by the faculty of the University of Wisconsin Medical School to facilitate their clinical practice of medicine in separate specialized groups, involving the deductibility of the partnership’s contribution of its business assets, including its goodwill, to the University of Wisconsin Medical Foundation, a non-private foundation formed to benefit the Medical School and its faculty by creating a single, integrated vehicle for the delivery of medical services.

Cascade Designs, Inc. – 2000

Successfully represented Cascade Designs, Inc., a Seattle-based manufacturer of camping and outdoor gear, in a U.S. Tax Court case involving the value of certain patents.

U.S. Bancorp and Subsidiaries – 1984

Successfully represented U.S. Bancorp, a regional financial services holding company, in an Oregon Tax Court case involving the Oregon excise tax treatment of the income of its Washington bank subsidiary.

Business Transactions

Sale of Business by Express Copy, Inc. – 2007

Represented the seller of the business assets of an Oregon-based provider of digital printing solutions to a newly formed subsidiary of InfoUSA, Inc., a publicly traded company.

Sale of Business by Huntington Investment Company – 2006

Represented the seller of the business assets of an Oregon-based distributor of automobile and golf cart parts and accessories to Nivel Parts & Manufacturing Co., LLC, a portfolio company of Sentinel Capital Partners.

Sale of Business by Quality Plastics Co., Inc. – 1994

Represented the seller of the business assets of an Oregon-based manufacturer of injection-molded plastic parts to Moll PlastiCrafters L.P.