Patrick G. Dooher has a broad, tax-related practice, with more than 20 years of experience advising individual, business and nonprofit clients on a variety of U.S. and international income and transfer tax issues, including the structuring of corporate and partnership acquisitions, mergers, redemptions and sales.
Together with other firm members, Patrick represented a firm client in a multi-step acquisition of a controlling general partnership interest in a National Basketball Association franchise. He has also structured taxable and nontaxable dispositions of realty; organized family limited liability companies and partnerships for business succession and transfer tax valuation purposes; and organized and advised §501(c)(3) public charities and private foundations.
Patrick also has over 20 years of experience representing clients before the IRS and in the Tax Court. He briefed, argued and won Halle v. Commissioner, 83 F.3rd 649 (4th Cir. 1996), a Fourth Circuit decision reversing the Tax Court on the issue of whether payments made to extend a contract settlement date were deductible as interest.
Cases that he has handled at the IRS audit and appeals level have involved such issues as the tax accounting methods used by a real estate construction company, a biotech firm and a computer networking/consulting company; the allocation of purchase price to subdivided realty; the reasonableness of compensation paid to officer/shareholders of a real estate construction company; and the tax exempt status of a private foundation engaged in social research activities and the prohibited transaction liability of the foundation’s founders.
Patrick has also developed a professional and personal expertise in the thoroughbred racing industry. Prior to its acquisition by Magna Entertainment, he was tax counsel to the Maryland Jockey Club, which owns the Maryland racetracks at Pimlico and Laurel. He has also represented race and show horse owners at the IRS audit and appeal levels and in Tax Court on §183 profit-motive issues.
He is a member, together with two other Washington attorneys, in the Nonsequitur Stable, LLC, a racehorse ownership group profiled by Andy Beyer in the Washington Post in January 1999 for its unusually (and unexpectedly) profitable activities. The group has campaigned several stakes-winning horses, including 1999 Maryland Million Classic winner Perfect to a Tee and the 2004 Triple Crown-nominated Water Cannon.
Patrick serves as deputy technical director for the Tax Management Portfolios U.S. Income series. For the past 40 years, Tax Management has produced more than 300 portfolios, monthly journals and periodicals, providing tax professionals and advisors with a sophisticated analysis, application and interpretation of the Internal Revenue Code.
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