Thought Leadership

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Author and Quote Source

  • Tom has been quoted or mentioned by name in The New York Times, The Baltimore Sun, Tax Notes, Tax Notes Today, BNA Daily Tax Report, Tax Law360, International Herald Tribune, The Kansas City Star, Financial Advisor Magazine, Chicago Lawyer,, Crain’s Health Pulse,, and
  • Recent Development:  Author of “The ‘Corporation’ Exception to Carried Interest:  A Litigator’s View,”  appearing at Federal Tax Notes, Vol. 169, p. 769 (Nov. 2, 2020) (5,200-word article addressing Code section 1061(c)(4)(A)).  Copy available upon request.  It appears that the Infrastructure Investment and Jobs Act (November 2021) did not amend section 1061(c)(4)(A), despite legislative proposals  
  • Recent Development:  Quoted in Law360’s article on the the Federal Circuit’s recent decision in Charleston Area Medical Center, which addresses Notice 2018-18 (respecting the TCJA’s cutback to the historically favorable treatment for Carried Interest)
  • Recent Development:  Quoted in Bloomberg/BNA’s article on the Federal Circuit’s recent decision in Charleston Area Medical Center, which addresses Notice 2018-18 (respecting the TCJA’s cutback to the historically favorable treatment for Carried Interest)
  • Recent Development:   Views as to the recent Charleston Area Medical Center decision, and its implications for the validity of regulations promised by IRS Notice 2018-18, addressed by Tax Analysts Contributing Editor Ben Willis’ in his LinkedIn blog
  • Quoted in Law360, “Tax Docs Irrelevant to Interest Row, US Tells 10th Cir.” Jan. 9, 2019 (pertaining to new Code section 1061(c)(4)(A))
  • Quoted in Bloomberg Law’s article, “IRS Clarification of Carried Interest May Face Legal Challenge,” March 22, 2018 (pertaining to new Code section 1061(c)(4)(A))
  • Quoted in Tax Law360 on recent decision requiring the filing of administrative claims before suing to recover additional statutory interest, Oct. 22, 2016
  • Author, “Litigation Finance for Tax Cases:  A Win-Win for Taxpayers and Counsel,” 153 Tax Notes 713, Oct. 31, 2016
  • Author, “10 Situations When a CPA Should Call ‘Timeout,’” Journal of Accountancy, April/May 2015
  • Author, “Additional Interest on FICA-Tax Refunds Made to Teaching Hospitals: Action Required,”, October 2014
  • Author, “Ruling Favors Employer Tax Refunds on Layoffs,” CFO magazine, September 25, 2012
  • Co-Author, “Could You Be Charged with A Crime for Failures by Prior Management to Pay Over Employment Taxes to the IRS?,” Orange County (CA) Business Journal, November 21, 2011
  • Author, “The Mayo Decision’s Problematic Tax Analysis,” BNA Daily Tax Report, March 17, 2011
  • Author, “De-Turbocharging Chevron and Mayo:  What Arguments Survive Mayo to Place a Check on Federal Regulatory Overreach?,”  Lexis-Nexis, April 27, 2011
  • Author, “Time for Teaching Hospitals to Conduct a Strategic Review of Large-Dollar Claims Seeking a Refund of Medical-Resident FICA Taxes Paid Under the 2005 Regulation,” BNA’s Health Law Reporter, August 19, 2010
  • Author, “Update on Next Steps for Teaching Hospitals to Recover FICA Tax Paid On Stipends Paid to Medical Residents,” Health Lawyers Weekly, June 18, 2010
  • Author, “Recovering FICA Tax Paid on Resident Stipends: 2010 Update,” hfm Magazine, April 1, 2010
  • Co-Author, “IRS Concedes That Medical Resident Stipends Are Not Subject to FICA Taxes for Quarters Before April 1, 2005: Now What?,” Health Lawyers Weekly, March 5, 2010
  • Co-Author, “Navigating Voluntary Disclosure in the Wake of the Government’s Assault on Undisclosed Foreign Accounts,” The Criminal Litigation Newsletter, American Bar Association, Spring 2009
  • Author, “Recovering FICA Tax Paid on Resident Stipends: Time for a Strategic Review,” hfm Magazine, January 2009
  • Co-Author, “Deductibility of Bribes, Kickbacks, Illegal Payments, Fines, and Penalties,” Tax Management Portfolio 524 (BNA/Bloomberg treatise), 2007
  • Co-Author, “Whose Tax Law Is It?,” Legal Times, October 16, 2006
  • Co-Author, “To Practice Tax Law, You Need A Patent License,” IP Law360, September 11, 2006
  • Co-Author, “Chapter 3850: Examinations: Audits, Assessments, Appeals,” BNA/Bloomberg’s Tax Practice Series, 2005
  • Co-Author, Supplement to major WG&L tax treatise regarding tax shelters (sub silentio).
  • Author, “The Invalidity of Reg. § 1.903-1(a) — and a Tax-Recovery Strategy Suggested by the Analysis,” Journal of Taxation of Global Transactions, Winter 2004
  • Author, “The Growing Controversy Over Federal Excise Tax on Long-Distance Calls,” The Tax Executive, May-June 2003
  • Author, “The Invalidity of the ‘For Everyone or No One’ Rule and a Tax-Recovery Strategy Suggested by the Analysis,” Tax Notes, February 1, 2003
  • Author, “Powerful New Arguments Against the Duplicated-Loss Provisions of the LDR,” Tax Notes, September 17, 2001
  • Author, Note, “Chart v. General Motors: Did It Chart the Way for Admission of Evidence of Subsequent Remedial Measures in Products Liability Actions?,” 41 Ohio St. L. J. 211 (1980) (student article in this Big Ten university’s flagship law review)

Notable Speaking Engagements

  • Speaker, Dedication of Monument with 40-Foot Flagpole in Memory of USMC Capt. Maurice R. Amundson; Dedicated at the 75th Anniversary Celebration of VFW Post 8338, Barron, Barron County, Wisconsin.  Captain Amundson, KIA on July 27, 1944, was posthumously awarded the Navy Cross for his fearless valor and an indomitable fighting spirit, in the best traditions of the Naval Service, while leading his USMC Company that spearheaded an attack against a particularly well-defended enemy position during the critical Second Battle of Guam.  The Navy Cross is the nation’s second-highest military honor.  Captain Amundson, the patriotic grandson of Scandinavian immigrants, enlisted in the Marines after graduating from St. Olaf College.  Thomas D. Sykes is the nephew of Capt. Amundson, his mother’s older brother
  • Panelist, Proposed Carried Carried Interest Regulations:  Are You Ready?, November 18, 2020 (sponsored by Anchin, Block & Anchin LLP; SS&C Technologies, Inc.; and Seward & Kissel LLP)
  • Speaker, “New Opportunities for Challenging Dubious Treasury Regulations,” Webcast Sponsored by the Tax Committee of the ABA’s Business Law Section, March 8, 2016 (with Prof. Andy Grewal of the U. of Iowa College of Law)
  • Speaker, “Bringing Suit to Recover Additional Interest on FICA Refunds Previously Received,” Webinar held on April 23, 2015
  • Speaker, “Update on ‘Third Wave’ Medical-Resident FICA Litigation,” Webinar held on November 21, 2013
  • Panelist, “Litigation of Actions under Section 7408 and Related Sections, Such as Sections 7407 and 7402,” ABA Section of Taxation and Section of Real Property, Trust and Estate Law, Trust and Estate Division’s 2012 Joint Fall CLE Meeting, Boston, MA, September 14, 2012
  • Speaker, “The IRS’s Revised Position on Employer-Provided and Supported Cell Phones,” The John Marshall Law School’s Tax Law Lunch and Learn Series, Chicago, April 18, 2012
  • Panelist, “Increased Scrutiny of Tax Professionals,” The John Marshall Law School Fourth Annual Institute on the Ethics of Tax Law Practice, Chicago, May 26, 2011
  • Panelist, “Medical Resident FICA,” National Association of College and University Business Officers’ Tax Forum, New Orleans, LA, November 4, 2010
  • Speaker, “A Look Back at the IRS’s Billion-Dollar Concession of Litigation over the ‘First Bucket’ of Medical-Resident FICA Claims: A View from the Front Lines,” The John Marshall Law School, Chicago, September 15, 2010
  • Speaker, “FICA Tax on Severance Pay: Status of the Controversy Possible Next Steps,” Ernst and Young LLP, Chicago, July 23, 2010
  • Participant, SUB Pay Meeting, Internal Revenue Service’s Office of Appeals, Washington, D.C., June 9, 2010
  • Panelist, “Shrinking Privileges, Expanding Responsibilities,” The John Marshall Law School Center for Tax Law and Employee Benefits’ Third Annual Institute on the Ethics of Tax Law Practice, Chicago, May 25, 2010
  • Panelist, 29th Annual Federal Tax Institute, Chicago-Kent College of Law, Chicago, April 29, 2010
  • Panelist, “Medical Resident FICA and Other Employment Tax Issues,” Ernst and Young LLP, Chicago, March 24, 2010
  • Panelist, “Focus on Tax Controversy: Managing Risk in a Hostile Environment,” Chicago, March 16, 2010
  • Panelist, “Employment Tax Update,” 19th Annual Ernst and Young LLP Health Sciences Tax Conference, Las Vegas, NV, December 8, 2009
  • Panelist, “International Compliance Issues,” TEI’s International Tax Forum, Chicago, December 3, 2009
  • Speaker, “The Report of Foreign Bank and Financial Accounts: Tough New Requirements,” Strafford CLE and CPE Webinar, November 5, 2009
  • Speaker, “Myriad Judgment Calls: Assisting Clients Who Have Failed to File Reports of Foreign Financial Accounts,” The John Marshall Law School Center for Tax Law and Employee Benefits’ Second Annual Institute on the Ethics of Tax Law Practice, Chicago, Illinois, May 15, 2009
  • Speaker, “Recovering Refunds of FICA Tax Paid on Stipends Paid to Medical Residents,” Webinar, May 6, 2009
  • Speaker, “Issues with IRC § 6694: Understatement of Taxpayer’s Liability by Tax Return Preparer,” The John Marshall Law School Inaugural Institute on the Ethics of Tax Law Practice, Chicago, Illinois, April 29, 2008
  • Panelist on the proposed overhaul of Rule 26(a) of the Rules of the Court of Federal Claims.  Tenth Annual Judicial Conference of the Court of Federal Claims, Kingsmill, Virginia, November 1997
  • Panelist and author of materials on prerequisites to tax-refund jurisdiction in the Court of Federal Claims.  Twentieth Annual Tax Law Conference of the Federal Bar Association, Washington, DC, March 1996

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