Gabriel Nuñez-Lafontaine practices in the areas of income tax and business planning as well as corporate law. His tax planning practice includes federal, state, and international tax planning for individuals and all types and sizes of businesses, including corporations, S-corporations, partnerships, and limited liability companies. His corporate practice involves representing clients in the acquisition and disposition of businesses, mergers, and federal income tax planning with regards to the choice of entity that best suits the client’s particular needs. Gabriel assists his clients in minimizing their tax burden while also accomplishing their business objectives.
Prior to joining the firm and beginning his LL.M. in Taxation at New York University, he was the General Counsel for SEG Management, LLC in Dallas, where he led negotiations and drafted lease agreements for commercial real estate in the healthcare space. Prior to that, he was an Associate with THEVOZ Attorneys, PLLC, in Austin where he advised clients on international tax issues including FBARs, streamlined compliance, voluntary disclosure procedures, and expatriation.
After graduating law school in 2017, Gabriel was employed as an Honors Hire in the Small Business/Self-Employed Division of the IRS, Office of the Chief Counsel in Austin where he worked as an attorney for over three years. While with Chief Counsel, he litigated various cases before the Tax Court on issues ranging from unreported income and disallowed deductions to penalties and additions to taxes. Gabriel drafted memorandums advising Revenue Agents and Revenue Officers on estate and gift tax matters, income tax issues, and collection matters—including foreclosures and seizures. In addition, Gabriel managed and coordinated two separate bankruptcy cases with over $150 million in assets with the Department of Justice Tax Division. Notable court opinions include: Frost v. Commissioner, 154 T.C. No. 2 and Weschenfelder v. Commissioner, T.C. Memo. 2019-133.
Mr. Nuñez-Lafontaine was admitted to practice in Texas in 2017 and is fluent in Spanish.
New York University School of Law, LL.M. Taxation, 2022
Recipient of the Wilf Tax Scholarship, 2021-2022
University of Colorado School of Law, J.D., 2017
Tax Emphasis, 2017
Certificate in Entrepreneurial Law, 2017
Entrepreneurial Law Clinic, Student Attorney, 2016-2017
University of Colorado Law Review, Associate Editor, 2016-2017 and Member, 2015-2016
Recipient of the George Bermant Award for Best Student Work in Corporate Law, 2017
Josef Korbel School of International Studies, University of Denver, M.A., 2014
Vanderbilt University, B.A., 2012
American Bar Association
Member
State Bar of Texas
Member
Dallas Bar Association
Member
Dallas Association of Young Lawyers
Member
State Bar of Texas, 2017
United States Tax Court, 2017
July 18, 2024
Adequate Disclosure Using the Form 8275-R in a Post-Loper Bright World...
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With the recent Supreme Court case in Loper Bright, tax practitioners are starting to consider whether certain interpretive Treasury regulations are still valid in a world without Chevron deference. As practitioners weigh whether to advise clients to take reporting positions that are contrary to Treasury regulations, it is important to keep in mind potentially applicable statutory penalties and ethical rules such as Circular 230.