United States Internal Revenue

James Hesler

** ****** *** *****, ****** Hill, NJ, 717-***-****, *****.*.******@*****.***

Education

Villanova University School of Law, Villanova, PA, LL.M. in Taxation, May 2011

Villanova University School of Law, Villanova, PA, J.D., May 2009

-Intern to Appellate Mediation Program, United States Court of Appeals for the Third Circuit, Philadelphia, PA (September 2008 - December 2008)

-Participated in Tax Clinic, January 2009 - May 2009

Franklin and Marshall College, Lancaster, PA, B.A., Business Administration (Finance Concentration), May 2006

Bar Admissions

Pennsylvania, admitted 2009 (voluntarily inactive).

Experience

Internal Revenue Service, United States Department of the Treasury, Newark, NJ. Appeals Policy Analyst (January 2023 – current).

Individually conduct and oversee comprehensive projects updating and modernizing the policies and procedures of the Office of Appeals. Individually responsible for oversight and development of forms, publications, and Internal Revenue Manual sections. Responsible for updating internal procedures to accommodate tax law updates and to create efficiencies. Coordinating and negotiating with all other IRS functions in order to create compatible procedures. Serving as coordinator of review, clearance, and approval process for procedural guidance and Internal Revenue Manual provisions. Served as instructor to new hires and served as temporary acting manager.

Internal Revenue Service, United States Department of the Treasury, Newark, NJ. Appeals Officer (August 2020 – January 2023).

Individually responsible for settling taxpayer appeals for docketed U.S. Tax Court cases, refund claims, requests for abatement, audit reconsiderations, and penalty appeals. Considered issues involving individuals, partnerships (including TEFRA and BBA partnerships), corporations, and S corporations. Handled a wide range of issues, including income recognition, employment taxes, accounting method, debt and equity considerations, validity of loans, business purchase structure, energy efficiency deductions, research credit, employee and contractor considerations, related party transactions, and fraud penalties. Responsible for significant tax law research. Personally prepared complex written legal analysis, as well as settlement documents and closing agreements. Frequently handled large caseloads and priority cases. Served as temporary acting manager.

Internal Revenue Service, United States Department of the Treasury, Philadelphia, PA. Appeals Officer - International Specialist (February 2017 – August 2020).

Individually responsible for settling taxpayer appeals for docketed U.S. Tax Court cases, refund claims, requests for abatement, audit reconsiderations, and penalty appeals. Handled cases featuring a variety of international components, including treaty-related issues, international withholding, Foreign Tax Credit, PFIC income, and disclosure penalties (such as Form 5471, Form 5472, Form 3520, Form 3520-A, and FBAR). Considered issues involving individuals, partnerships, corporations, and trusts. Prepared tax computations. Conducted mediations. Served as instructor and temporary acting manager.

Internal Revenue Service, United States Department of the Treasury, Philadelphia, PA. Appeals Officer (September 2011 – February 2017).

Individually responsible for settling taxpayer appeals for docketed U.S. Tax Court cases, refund claims, requests for abatement, and audit reconsiderations. Considered issues involving individuals, S corporations, C corporations, partnerships, estates, and non-profit organizations. Collaborated on, and managed, inter-departmental projects to increase efficiency. Prepared tax computations. Conducted educational presentations for colleagues. Developed and managed an area-wide training program. Served as instructor and temporary acting manager.

Internal Revenue Service, United States Department of the Treasury, Philadelphia, PA. Tax Compliance Officer (August 2009 – September 2011).

Examined individual and small business tax returns. Conducted tax law presentations for colleagues, and instructional seminars for trainees. Assisted IRS Chief Counsel with preparation of docketed cases. Conducted foreign collateral requests (international information sharing).

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