Morrison & Foerster LLP
James Merritt engages in all aspects of tax litigation. Mr. Merritt's federal tax litigation practice includes civil and criminal litigation, audits, and investigations. He has appeared at all administrative levels of the Internal Revenue Service, Treasury Department, and other agencies. He has worked extensively on complex investigations that require coordination between various federal and state agencies. Mr. Merritt has tried a substantial number of federal tax cases in various forums, as well as numerous state and local tax cases. He is admitted to practice before the United States Tax Court and the United States Claims Court as well as various United States district courts, state trial courts, and appropriate appellate courts, including the United States Supreme Court. He has also represented attorneys and accountants in investigations and litigation involving their advice and assistance to their clients. Mr. Merritt's dispute resolution experience includes complex fact issues involving valuation, inventory, and tax accounting methods, transfer pricing (Section 482), investment tax credit, etc., as well as other sophisticated legal issues.
Mr. Merritt was chair of the American Bar Association's Section of Taxation Committee on Administrative Practice, of the Committee on Employment Taxes, and the Committee on Special Projects. He also chaired the American College of Tax Counsel, a Tax Force on Director of Practice and Civil Penalties of the Administration Practice Committee, a Subcommittee on the Civil Penalties Tax Force, and the Small Business Subcommittee on the Compliance Tax Force Tax Section of the American Bar Association. He is a Master in the J. Edgar Murdock Inn of Court (Tax).
From 1964 to 1968, Mr. Merritt served as Trial Attorney and Regional Counsel for the Internal Revenue Service in San Francisco, California. In 1983, he served as a consultant in the Office of the Chief Counsel for the Internal Revenue Service.