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HERMAN J. MARINO

J.D., L.L.M.

Address: *** ***** ****** *****, ***** 200

Naples, Florida. 34113

847-***-****

ad2v0y@r.postjobfree.com

www.marinolaw.net

ad2v0y@r.postjobfree.com--

linkedin.com/in/herman-marino

IRS Dispute Resolution and Litigation – Tax Planning for High-Net-Worth Businesses

Domestic & Offshore Clients and Transactions

Senior-level executive with over 15 years of experience. Provides exemplary tax oriented leadership, conducts legal research and due diligence, oversees various forms of business creation and dissolution, offers consultation on high-net-worth asset protection, administers tax planning, and establishes domestic and offshore trusts. Achieves legal excellence by adapting readily during times of crisis and uncertainty and in fast-changing legal environments by employing calm, confident, supportive, and decisive leadership.

Serves as a trusted advisor and confidant to domestic and international clients, fellow attorneys, compliance and regulatory officials, and federal agencies. Cultivates profitable business relationships through effective communication and thrives in client-focused environments. Drives business development and revenue with a thorough understanding of the law, adeptly navigating the legal community and court systems. Additional competencies include:

Tax Audits/

Dispute Resolution:

o Federal and state (Illinois) audits and administrative protests; appeals to IRS.

o Focus is on reducing or eliminating IRS/state audit adjustments by 30-40% through review and

amendment of return under audit.

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o Reduce income tax liability by filing tax elections to reduce or defer tax costs.

o Negotiation of offers in compromise and settlement of IRS levies/liens to reduce or eliminate liability per IRS assessments.

Tax Planning:

o Income estate and gift tax planning for high-net worth individuals and businesses, small and mid-

sized corporations, limited liability companies,

subchapter S Corporations, general and limited

partnerships.

o Includes preparation of requests for Private Letter Rulings with IRS for, e.g., 368 B and C

reorganizations and tax recommendations to defer or eliminate tax liabilities for various issues, including deferred compensation plans.

LICENSES:

Professional Member, Florida, Illinois and Nevada Bars Other Professional

Associations: Passed Illinois C.P.A. Exam (unlicensed). Passed C.F.P. Exam (unlicensed)

Court Bar Memberships: U.S. Supreme Court

U.S. Court of Appeals for the Seventh Circuit.

U.S. Court of Appeals for the Fourth Circuit.

U.S. Court of Appeals for the D.C. Circuit.

U.S. District Court, Northern District of Florida. U.S. District Court, Middle District of Florida.

U.S. District Court, Southern District of Florida. U.S. District Court, Northern District of Illinois. U.S. District Court, Nevada.

U.S. Tax Court.

U.S. Court of Claims.

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CAREER SYNOPSIS

DA Partners Technical Services Group LLC 2024-present Retained as Tax Expert to provide remote advice to INTUIT customers and clients on income tax planning and compliance issues for 2023 and 2024 tax years. Herman J. Marino, Ltd., PC, Chicago, IL Pre-2000-present. Law firm providing comprehensive and cost-effective legal guidance in all phases of income, estate, gift, and employment tax compliance and litigation. Provide: (i) advice to domestic and global clients on legal concerns and case-pertinent issues and research; (ii) draft tax refund complaints; (iii) review case-specific documentation; provide litigation in the small business, real estate, probate, and administration arenas;

(iv) due diligence for the formation and ongoing oversight of limited liability companies, subchapter S corporations, and general partnerships. Herman J. Marino Tax Planning and Resolution PA, 2022-present. Law Firm organized in Florida to provide: (i) comprehensive and cost-effective legal guidance in all phases of income, estate, gift, and employment tax compliance and litigation; (ii) review income, estate, gift, and employment tax compliance issues for clients; (iii) adjudicate of tax matters in US District and Tax Courts; (iv) negotiate delinquent IRS tax accounts; and, (v) file protests and appeals in district and appellate courts.

Earlier Career Experience as a senior editor, tax research and planning manager, international tax manager, and tax accountant at Commerce Clearing House, Inc., Diamond Shamrock International Company, Price Waterhouse, and Arthur Andersen. 4

EDUCATION, TEACHING, TRAINING, CERTIFICATIONS, LICENSES, & TECHNICAL PROFICIENCIES

DePaul University School of Law, Master of Laws in Taxation. Northwestern University, Chicago, Juris Doctorate in Law The Loyola University of Chicago, Bachelor of Science, Summa Cum Laude North Park University, Adjunct Professor in Business Law Arthur Andersen Training Center, Lecturer in International Taxation Past Licensure, Certified Public Accountant (Illinois), Certified Financial Planner Technical skills: MS Office Suite, Intuit, Zoom, Skype/Teams, Asana, Google Suite PROFESSIONAL ASSOCIATIONS, PRESENTATION, PUBLICATION, AWARDS, & COMMUNITY INVOLVEMENT

Publications: “The US. Taxation of Foreign Exchange Gains and Losses: An Analysis of the Treasury Discussion Draft”

“The Partnership Anti-Abuse Regulation: The Treasury Redefines the Intent of Subchapter K Taxes”

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