G. Michelle Ferreira SHAREHOLDER

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1 G. Michelle Ferreira SHAREHOLDER SAN FRANCISCO 4 Embarcadero Center Suite 3000 San Francisco, CA SILICON VALLEY 1900 University Avenue 5th Floor East Palo Alto, CA G. Michelle Ferreira is Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards. As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages. Michelle has 18 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses. Concentrations Tax compliance advice Civil tax disputes, including audits, appeals and collection matters Offshore income tax disputes, foreign income, bank and asset reporting and related penalty assessments Complex tax litigation Criminal tax investigations and litigation Tax shelter investigations, audit and litigation Taxing agencies information document requests Tax procedure Tax shelter promoter audits and investigations Estate and gift tax disputes Tax penalties Education J.D., Santa Clara University School of Law, 1995 B.S., University of California at Davis, 1990 Admissions California Supreme Court of California U.S. District Court for the Northern District of California U.S. District Court for the Central District of California U.S. Tax Court 2018 Greenberg Traurig, LLP

2 CLAUDIA HILL, EA, MBA Tax Mam, Inc./TMI Tax Services Group, Inc Pacifica Drive, Suite 100 Cupertino, CA Talk Fax Claudia Hill is an Enrolled Agent, nationally recognized tax professional and frequent lecturer on taxation of individuals and representation before IRS. She is Editor in Chief of the WoltersKluwer, (formerly CCH) Journal of Tax Practice & Procedure, co-author of CCH Expert Treatise Tax Practice & Procedure, a founding partner of Tax Genius Learning, and a frequent presenter for both audio and in-person CPE seminars nationwide. Claudia coordinates a dream team of tax controversy advisors for the IRS Watch blog on Forbes.com ( She was named a Top Ten Nominee by Tax Analysts as 2011 Person of the Year. Claudia is owner and principal of Tax Mam, Inc. and TMI Tax Services Group, Inc. in Cupertino, CA. TMI Tax Services Group offers tax return preparation, tax planning, and tax problem resolution and representation services, primarily to individual clients. She is often called upon by the news media as a resource person for commentary on tax topics. Her articles and observations have appeared in CCH publications as well as Tax Analysts, Forbes.com and industry professional journals. Her mission to reform or eliminate the individual AMT has been the focus of a number of articles. In March 2005, Claudia was invited to testify about the individual AMT at the President s Tax Reform Panel. Visit her website, Claudia has testified before the Senate Finance Committee on Tax Law Simplification, before the House Government Relations Subcommittee hearing on IRS Administration and Filing Season Readiness, before House Ways & Means Oversight Committee on Taxpayers Who Fail to File Federal Income Tax Returns, before the House Small Business Subcommittee on Independent Contractors, and before the Treasury Department at regulations hearings on tax practice. She continues to work with National IRS and practitioner groups on IRS policy related issues. She annually writes & teaches courses for the IRS Nationwide Forums on behalf of the National Association of Enrolled Agents. She was both a panelist and moderator for The New IRS Stands Up, a key IRS-private sector conference held in January She has participated numerous times on Tax Talk Today, the internet TV Tax Show for the Tax Pro, most recently the May 2012 Ethics Under Circular 230: Need-to-Know Standards for Tax Return Preparation and November 2013 Tax Planning and Reporting Issues for Savers and Investors Claudia is an associate member of the ABA Tax Section, a life member of the American Tax Policy Institute, a Fellow and former Dean of the NAEA-EF National Tax Practice Institute. After several years as Chair, Ms. Hill is now a special advisor to the Government Relations Committee for the National Association of Enrolled Agents. She served on the 1987 Commissioner's Advisory Group to the National Office of the Internal Revenue Service. Ms. Hill holds a Master degree in Business Administration, earned with honors in January 2018

3 Biography of Steven L. Jager, CPA, MST, USTCP Mr. Jager is the Founder and Principal of Steven L. Jager, CPA, An Accountancy Corporation. The Firm is a boutique accountancy Firm with a special emphasis in tax controversies and accountancy services to individuals and closely-held businesses. Mr. Jager is a member of the American Institute of Certified Public Accountants; the California Society of Certified Public Accountants; the Society of California Accountants; an associate member of the American Bar Association; and the Federal Bar Association. In addition, Mr. Jager is an associate member of the California State Bar, Taxation Section, and is among a small handful of Non-lawyers in California to presently serve as an active member of the State Bar Committee on Tax Procedure and Litigation. Mr. Jager is admitted to practice in the United States Tax Court. In the entire United States, fewer than 300 non-lawyers hold the distinction being admitted to the Bar of the United States Tax Court. Mr. Jager holds a Masters Degree in Taxation from California State University, Northridge. He received his B.A. degree from UCLA in Subsequently he studied Accounting, Finance and Marketing at California State University, Los Angeles and obtained his California CPA Certificate in Mr. Jager has been in public accountancy practice since His former employers include a national CPA Firm and prestigious local firms. In 1988, he established his own Firm. Since 1992, Mr. Jager has been a regular and popular instructor at the UCLA Extension Department of Business and Management. In the Spring of 2005, UCLA Extension proudly launched their newest course, Ethics in Accountancy, which was developed and written by Mr. Jager in response to President Bush s request of our nation s business schools to teach ethics courses as part of the business school curriculum. Mr. Jager is also an adjunct Professor at California State University, Northridge, where he teaches in the Masters of Taxation program and in the Masters of Professional Accountancy program. Mr. Jager has authored several articles and lectures frequently to business and professional groups. Best Practices To Reduce Your Chances of Being Sued as a Tax Professional, Page 2 of 10 pages 2018 Steven L. Jager, CPA, MST, USTCP - All Rights Reserved

4 Philip J. Wilson TAX & BUSINESS SERVICES Philip J. Wilson is office managing partner of Marcum s Irvine, California, office and is leader of the Firm s national Tax Controversy group. Mr. Wilson has more than 30 years of CPA and business advisory experience, including experience as an IRS revenue agent. Mr. Wilson focuses on helping individuals and companies resolve tax controversies with the Internal Revenue Service, representing all types of businesses as well as high net worth individuals. Prior to joining Marcum LLP, Mr. Wilson was a founding partner of WilsonMorgan LLP, based in Irvine. He oversaw all of the firm s tax compliance, tax consulting, and tax controversy engagements. He has substantial experience in the real estate area, including tax structuring for commercial and residential developers, and has worked with clients in a wide variety of industries. Professional & Civic Affiliations American Institute of Certified Public Accountants (AICPA) California Society of Certified Public Accountants (CalCPA) Pacific Club IMPACT Foundation Board member Orange County YMCA former Board member Philip J. Wilson, CPA* Office Managing Partner SUBJECT MATTER EXPERTISE Real Estate Tax Controversy Strategic Tax Planning and Compliance PRACTICE FOCUS Privately Held Companies Entrepreneurial High Net Worth Individuals EDUCATION Western Carolina University Bachelor of Science in Business Administration, Accounting Concentration Golden Gate University Masters in Business Taxation *Licensed by the State of California Phone philip.wilson@marcumllp.com

5 John Tuzynski IRS - SB/SE Legislative Implementation Lead John was born and raised in Erie, Pennsylvania and attended Penn State University Behrend campus, where he earned a bachelor s degree in Accounting with a minor in Economics. John has held many positions throughout his 33-year career at IRS ranging from Revenue Agent to frontline and senior manager positions in various field and headquarters functions. This includes serving as the national program manager for flow-through entities, unreported income and market specialization. In 2004, John became the first Chief of Employment Tax with national program responsibility for IRS Employment Tax Policy and Employment Tax field operations until During that time, John also implemented some early provisions of the Affordable Care Act. From October 2015 through October 2017, John assumed the position of Director, Examination Technical Services where he was responsible for providing executive leadership and direction over the technical review and procedural support of field and office examination for both the Small Business/Self Employed (SB/SE) and Large Business & International (LB&I) business operating divisions. John has also served as the Acting Area Director, Field Examination, in the North Atlantic, South Atlantic and Western Areas and currently is the Director, Examination, Central Area. At present, he is on a detail assignment implementing 29 provisions of the 119 provisions of the Tax Cuts and Job Act. John is married to Laurie, who also works at IRS, and has a son Philip. He resides with his wife and two cats, Smudge and Sabrina, in the state of Maryland.