ERIC MAHLER

**** **** **** *****

Pickerington, Ohio 43147

Home phone: 614-***-****

Email: abmc2y@r.postjobfree.com

Objective: to secure a position performing tax controversy services which includes

managing audits, handling administrative appeals, and performing tax litigation. I also

would like to perform tax planning services this would also include assessing the need for

a FIN 48 reserve where necessary.

Vice President of Tax - December 2000 to Present - DSW, Inc and Retail Ventures,

Inc., Columbus, OH. DSW is a publicly traded shoe retailer with approximately 1.7

billion in revenues. RVI is a publicly traded holding company which previously operated

two retail divisions called Value City Department Stores and Filene’s Basement. Value

City previously had approximately 1 billion in annual revenues and Filene’s had

approximately .5 billion in annual revenues.

• Successfully argued for a federal accounting method change in a “Conference of

Right” on a Tier II issue. We received a favorable ruling permitting our requested

method change.

• Successfully closed 3 IRS audit cycles that included 2 joint committee cases as

well as received refunds within 8 days after filing returns.

• Successfully argue before the Pennsylvania Board of Revenue and Finance a

common pay agent case. We received ruling in our favor removing the

assessment in full.

• Successfully argued administrative appeals in MA (4 sales and use tax cases), PA

(1 sales and use tax case), OH (3 sales and use tax cases). Settled other sales and

use tax cases at the examination level. Currently have cases pending in TX, NY,

and MA.

• Perform tax planning (federal, state, and transfer taxes) and analysis on 2 internal

reorganizations, an IPO of subsidiary DSW, and 2 disposition transactions that

included an IRC 338(h)(10), 165(g), and a stock sale.

• Reached settlements in NY and IL on combined filing issues.

• Regularly assist staff with penalty abatement requests.

• Perform quarterly FAS 109 and FIN 48 computations and analysis.

• Perform FAS 109 footnote compilation.

• Review federal, state and local tax returns for filing.

• Manage a staff of 4 to 6 professionals and an hourly associate. This included

hiring, annual reviews, terminations, and employee motivation and discipline.

• Report to CFO and participate occasionally in audit committee or board of

director meetings.

Audit Manager – 2000 National City Bank., Cleveland, OH National City Bank was a

publicly traded domestic company with approximately $8B in revenues. It had customary banking

operations such as depository accounts, checking accounts, and credit card services, commercial

financing, mortgage loans, personal investment management, trust management, etc.

• Handled IRS IDR responses, protest drafting, argued at administrative appeals hearings.

• Argued at IN administrative appeal hearing on a franchise tax case and drafted protest on

OH franchise tax issue.

Tax Manager – 1996 to 2000 Spitzer Management, Elyria, OH. Spitzer

Management is a privately held company operating approximately 24 automobile

dealerships, 2 marinas, a hotel, country club, and various real estate ventures.

Approximately $800K in annual revenues.

• Drafted 55 protests for federal audits and appeared on all cases in the

administrative appeal process. I was able to settle most cases.

• 6 cases docketed at US Tax Court – all cases settled prior to trial.

• Filed 3 FOIA requests.

• Handled all federal audits. This included information requests and

negotiations with auditors and their managers.

• Worked on restricted statute of limitations issues.

• Filed protective claims where necessary.

• Performed all tax planning for federal and state income and franchise tax

matters.

• Performed tax return compliance for all federal and state tax returns.

• Performed tax planning for shareholder buy outs, acquisitions,, roll up of

corporate entities, and liquidations.

Revenue Agent 1987 1996 Internal Revenue Service

• Audited numerous corporate, partnership, and individual returns. This

included complex issues such as mergers, acquisitions, and LIFO inventories.

• Independently manage a caseload, which includes selecting returns for audit,

interviewing taxpayers, auditing books and records, discussing and settling

issues, researching issues and writing reports.

• Perform public speaking, which includes giving speeches to civic groups and

teaching professional education classes to non government professionals.

• Reviewing unagreed cases and writing statutory notices of deficiency. Assist

District Counsel by researching, writing and auditing.

• Trained as an expert witness for criminal tax cases. Assisted the U.S.

Attorney as an expert in three criminal tax cases.

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EDUCATION

• Juris Doctorate University of Akron, 1994 Tax moot court team, 15

hours of tax and 6 hours of trial advocacy.

• BBA Accounting University of Texas at Arlington, 1987

• Associates Degree Ricks Junior College, 1982

PROFESSIONAL QUALIFICATIONS

• Attorney admitted to practice in Ohio and before the US Tax Court

• Certified Public Accountant licensed in Ohio (non practicing)

1.

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