Profile

With over 35 years of corporate tax experience, Pat assists clients with all aspects of federal income taxation.

Pat brings a practical approach to negotiating and structuring acquisitions and dispositions of assets and entities; structuring taxable and tax-deferred dispositions of real estate assets and corporate aircraft, structuring and negotiating partnership and limited liability company agreements; and resolving business disputes and IRS examinations.

His extensive business and legal experience has included serving as the principal advisor to numerous closely held companies and family-owned businesses.

Relevant Experience

  • Serves as tax counsel to a large number of REITs and real estate investors in connection with like-kind exchange transactions.
  • Represents clients in negotiating, structuring and financing the acquisition and disposition of private aircraft, including tax-deferred like-kind exchanges of aircraft and state and local tax planning. 
  • Negotiates and structures asset purchase and stock purchase transactions, including the sale of a $1 billion closely held financial institution. 
  • Broad experience relating to the formation and structuring of partnerships, limited liability companies and corporations. 
  • Provides tax and transactional counsel on numerous aspects of commercial real estate transactions. 
  • Extensive experience negotiating and documenting settlement of business disputes.
  • Successfully resolved IRS examinations relating to the sale of corporate subsidiaries, thoroughbred horse racing operations and the operation of corporate aircraft.

Bar Admissions

    Education
    JD, University of Virginia, 1982BS, Christian Brothers College, 1979

    Areas of Practice

    • Tax

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