Mitchel R. Cohen

Email: mcohen@duffykekel.com
Phone: 971-244-1812

Mitchel R. CohenAreas of Practice

Business counsel

Charitable planning and organizations

Estate planning

Mergers & acquisitions

Probate and trust administration

Tax dispute resolution
 
Mitch’s practice focuses on Federal, state and local income, excise, gift and estate tax, including related business matters, estate planning and probate. He assists clients in structuring business transactions with an eye to minimizing tax effect. He represents taxpayers before the Internal Revenue Service and state and local tax authorities in audits and appeals, and in obtaining tax ruling letters, including from the IRS National Office in Washington, D.C. He assists clients with the organization and operation of charitable and other nonprofit organizations. He prepares simple and complex wills and trusts, assists clients with estate tax reduction strategies, and prepares estate, gift and generation-skipping transfer tax returns. He advises condominium and other homeowner associations on the special income tax treatment of such organizations. He has represented Alaska Native Corporations and Native American Tribes and has particular expertise in the special income tax rules and issues faced by ANCs.

Admitted to Practice

District of Columbia
Oregon
Washington
United States Supreme Court
United States District Court, District of Oregon United States Tax Court

Education

LL.M., New York University, 1977

Graduate Editor, Tax Law Review (1976-1977)

J.D., Gonzaga University, 1976, magna cum laude Editor, Gonzaga Law Review (1975-1976)

B.A., Colgate University, 1973

Memberships & Activities

Oregon State Bar Association: Member, Sections on Taxation (Executive Committee, 1986-1990) and Estate Planning

American Bar Association: Member, Sections on Taxation and Real Property, Probate and Trust Law

Western States-IRS Liaison Committee: Member, 1995-2016; Secretary (2001 & 2011), Vice Chair (2002 & 2012), Chair (2003 & 2013)

Estate Planning Council of Portland, Inc.

Portland Tax Forum: Member, Board of Directors, 2010 – Present

Publications

Tenancy in Common – An Alternative to Partnerships or LLCs, Oregon State Bar, Vol. 1 Advising Oregon Businesses Ch. 7 (2017) (Co-author)

Representative IRS Rulings Obtained for Clients

IRS Chief Counsel Memo. (ILM) 201013036 (11/10/09) – income tax basis of Alaska Native Claims Settlement Act land (first commercial development)

IRS Chief Counsel Memo. (ILM) 200949038 (8/3/09) – income tax deduction

IRS Private Ruling 200147013 (7/7/01) – deduction vs. capital expenditure

IRS Private Ruling 200027019 (4/5/00) – tax status of Indian Tribe

IRS Private Ruling 9522051 (3/3/95) – trust income taxation

IRS Private Ruling 9049041 (12/7/90) – estate and generation-skipping transfer taxes IRS Private Ruling 8417001 (10/12/83) – timber depletion