Larry is a Director in KPMG LLP (KPMG)’s Washington National Tax - Practice, Procedure, and Administration group, assisting clients on matters falling under I.R.C. Subtitle F on subject matter including: collection, refund, penalty and penalty relief, statutes of limitation, entity classification, section 9100 relief for missed elections, private letter ruling requests, and other federal tax procedure, compliance, and controversy issues.
Larry joined KPMG after nine years with the IRS Office of Chief Counsel, Procedure, and Administration Division (P&A), where he served as acting Deputy Chief Counsel and was branch chief in the practice group responsible for appeals, assessment, collection, estate tax extension, refund, abatement, TFRP, and transferee liability issues. Prior to serving as branch chief, he was a senior technician reviewer responsible for return, extensions for filing and paying, statutes of limitation, penalty, return/practitioner, and electronic tax administration issues. In these roles, he provided advice to and on behalf of the Associate Chief Counsel (P&A) and its senior leadership team, helping formulate and develop recommendations on, and implement strategic solutions for, the regulatory, policy, and litigation challenges faced by the IRS. He was the primary drafter and/or reviewer of various procedure related regulations and guidance. Prior to joining Chief Counsel, Larry worked for two litigation firms where, among other things, he advised clients on tax procedure, compliance and penalty issues, and another Big Four firm.
Larry has been a speaker and panel member before numerous groups including the Federal Bar Association, the American Bar Association, and the Tax Executives Institute, and he has written extensively on numerous federal tax procedural issues