Marcus is a principal with over 15 years of providing tax and business advisory services.
As one of the leaders of Withum’s Tax Controversy practice, he has extensive experience in resolving federal, state and local tax controversies including, but not limited to, matters involving Tax Examinations, Appeals, Collections, Innocent Spouse, Responsible Party, and Offer-in-Compromise.
In addition, he has experience in the field of law representing clients in commercial and tax disputes before state courts, Federal District Court and the United States Tax Court. Marcus also has extensive experience in alternative dispute resolution, which he frequently used to resolve disputes by means other than litigation.
As for business transactions, he has experience in drafting, reviewing and negotiating the language of a wide array of transactions documents including, but not limited to, buy/sell agreements, portfolio management agreements, swap agreements, limited liability company agreements and indentures.
He is admitted to practice law in Federal District Court as well as United States Tax Court.
Learn more about my professional experience and how I spend my time outside the firm.
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The Tax Court’s recent decision in Bowen v. Commissioner provides new guidance on the scope of potential Covid-era refund claims arising from Kwong v. United States. To understand the ramifications of Bowen for taxpayers who are potentially eligible for refunds under Kwong, it is helpful to begin with what the Kwong case established. What Kwong Established The…
IRS Chief Tax Compliance Officer Jarod Koopman recently indicated that the IRS is considering creating a portal, in light of Kwong v. United States, 178 Fed. Cl. 295 (2025), to help taxpayers who may be entitled to refunds of COVID-era interest and penalties submit and track their refund claims. The announcement comes as the IRS…
The appeal many expected has arrived, but the real question is what comes next. For months, taxpayers and practitioners have wondered whether the IRS would ultimately accept the implications of Kwong v. United States or continue defending its interpretation of the COVID-era relief provisions under IRC §7508A(d). We now have part of that answer. The…