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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

901 Main Street, Suite 3700
Dallas, TX 75202

Phone: 214.744.3700
Fax: 214.747.3732
Toll Free: 800.451.0093

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J. Daniel Boysen

Mr. Boysen practices in the areas of Income Tax Litigation, Income Tax and Business Planning, White Collar and Government Regulatory Litigation, Estate and Gift Tax Litigation, and State Tax Planning and Litigation.  He represents individuals, estates, partnerships, closely-held businesses, and large corporations in all stages of a tax dispute, including IRS examinations, administrative appeals, and litigation in U.S. Tax Court, Federal District Court, and the Court of Federal Claims.  His practice includes all aspects of business tax planning, such as entity formation, restructuring of ownership interests in entities, acquisitions, and dispositions. Mr. Boysen's practice also concentrates on resolving white collar criminal investigations and representing taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies.

Prior to joining the firm in 2015, Mr. Boysen was a Tax Associate with a national accounting firm.

Mr. Boysen was admitted to practice in Texas in 2013.

  • Georgetown University Law Center, LL.M. in Taxation, with distinction, 2014
  • Pepperdine University School of Law,, J.D. and Certificate in Law & Entrepreneurship
    • Senior Staff Member, Pepperdine Law Review, 2011-2013
    • Dean's Honor List (Fall 2011)
    • CALI Awards for Highest Grades in Negotiation Theory & Practice, Entrepreneurship, Ethical Lawyering, and Securities Regulation
  • Baylor University, B.B.A., Finance and Economics, magna cum laude, 2010
    • Dean's Honor List
    • Supplemental Instructor, Financial Accounting Course
  • State Bar of Texas
    • Member, Tax Section
  • Dallas Bar Association
    • Member, Tax Section
  • Dallas Association of Young Lawyers (DAYL)
  • U.S. District Court Northern District of Texas
July 12, 2017

The Treasury Targeting the Recent Section 385 Debt-Equity Regulations (and Others) for Potential Repeal... [ read ]

On Friday, July 7th, the U.S. Department of the Treasury (the "Treasury") announced in Notice 2017-38 that it is targeting eight tax regulations for potential repeal. Included in the eight targeted are the final section 385 regulations issued in October of 2016. In a previous article from December of 2016, I discussed the onerous documentation requirements under the final section 385 regulations for related-party debt and touched on what effect these requirements may have on closely-held corporations. The Treasury's announcement could prove as a relief to those corporations dreading the potential financial burden resulting from the new documentation requirements.

February 17, 2017

The Third Court of Appeals in Agri-Plex Finds that a Business Buyer May Not Be Able to Escape Successor Liability for Hidden Tax Liabilities Assessed After Purchase... [ read ]

On January 19, 2017, the Texas Third Court of Appeals (the "Court") in Agri-Plex Heating and Cooling, LLC v. Hegar found that a business buyer may not be able to escape successor liability for hidden tax liabilities assessed after the purchase occurs. Agri-Plex Heating and Cooling, LLC v. Hegar, No. 03-15-00813-CV (Tex. App.-Austin January 19, 2017, no pet. h.) (mem. op.)). As a result and moving forward, a buyer purchasing a business should be cautious and plan accordingly because it could be liable for taxes incurred by the seller before the purchase but not known or ascertainable by either party at the time of closing.

January 17, 2017

Recently Revised Opinion in American Multi-Cinema, Inc. v. Hegar Narrows Its Previously Broad Scope... [ read ]

On January 6, 2017, the Texas Third Court of Appeals (the "Court") withdrew their opinion and judgment in American Multi-Cinema, Inc. v. Hegar from April 30, 2015 to substitute a revised opinion (No. 03-14-00397-CV (Tex. App.—Austin January 6, 2017, no pet. h.) (mem. op.)). The revised opinion upholds American Multi-Cinema, Inc.'s ("AMC's") cost of goods sold ("COGS") deduction for its film exhibition costs while leaving unresolved whether AMC's products are "perceptible to the senses" and thus qualify as "tangible personal property" under Texas Tax Code Section ("Section") 171.1012(a)(3)(A)(i).

January 5, 2017

The IRS Increases Taxpayer Entrance Fees for Installment Agreements While Adding Reduced Online Option... [ read ]

On December 2, 2016, the IRS issued final regulations outlining increased installment agreement entrance fees while adding a reduced fee for online payment agreements. The change in installment agreement entrance fees will apply to installment agreements entered into on or after January 1, 2017.

December 29, 2016

IRS Finalizes Documentation Requirements for Related-Party Debt: The Regulations and Their Effect on Closely-Held Corporations... [ read ]

In October of 2016, the IRS issued final regulations under IRC code section 385. The final regulations cover a number of issues under Internal Revenue Code ("IRC") section 385. IRC section 385 deals, in general, with whether an interest in a corporation should be treated as stock or debt for federal income tax purposes. The purpose of this article is to discuss the documentation requirements under Treas. Reg. § 1.385-2 for related-party debt and touch on what effect these requirements may have on closely-held corporations.

August 25, 2016

IRS Releases Procedure for Amending a Streamlined Submission... [ read ]

On July 18, 2016, the IRS released for the first time the procedure for amending a streamlined submission, as part of ongoing updates to its Frequently Asked Questions for U.S. Taxpayers Residing in the United States and for U.S. Taxpayers Residing Outside the United States .