IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
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IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
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IRS Further Extends Deadline for 2009 and Prior FBARs Required to be Filed by U.S. Persons With Signature Authority but No Financial Interest in Foreign Accounts

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
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Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
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Certain Taxpayers May Avoid Penalties If They File Delinquent Information Returns Relating to Foreign Accounts, Foreign Entities, and Foreign Gifts

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
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IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
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IRS Issues Relief from FBAR Filing Obligations for Three Groups

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
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IRS Extends Deadline For Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
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Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
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A Tax Opinion Is Not A Bulletproof Vest

by Richard A. Levine
Published: The Metropolitan Corporate Counsel, November 01, 2004
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Internal Revenue Service Reconstruction and Reform Act of 1998

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, September 01, 1998

Newsletter -- June 1998 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, June 01, 1998

Newsletter -- January 1998 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, January 01, 1998

Taxpayer Relief Act of 1997

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, October 01, 1997

Newsletter -- February 1997 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, February 01, 1997

Newsletter -- November 1996 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, November 01, 1996

Richard A. Levine, for more than 30 years, has represented clients in a wide variety of tax controversy and litigation matters involving federal and New York State and City taxes. His experience spans a full range of civil and criminal tax audits and investigations. He has tried tax cases before the U.S. Tax Court, the U.S. Court of Claims and in various federal District Courts. He has also argued appeals to the U.S. Circuit Courts of Appeal. He co-authored BNA Tax Management Portfolio Tax Court Litigation and published numerous articles on the Tax Court's Rules of Practice and Procedure. He also represents clients in New York State and City tax litigation in matters involving income tax, sales tax, real property transfer taxes and residence issues.

He received a B.S. cum laude from the Wharton School of the University of Pennsylvania, his LL.B. magna cum laude from Harvard, where he was a member of the Law Review, and an LL.M. from New York University.