Mr. Budd 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. Budd'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. Mr. Budd served as a Judicial Extern for the Honorable Judge Sally Pokorny of the Douglas County District Court in Lawrence, Kansas.
Mr. Budd was admitted to practice in Texas in 2017 and in Missouri in 2015.
- New York University School of Law, LL.M. in Taxation, 2016
- University of Kansas School of Law, J.D., 2015
- Kansas Law Review, Managing Editor
- Published Comment, "All Work and No Pay: Establishing the Standard for When Legal, Unpaid Internships Become Illegal, Unpaid Labor," 63 U. Kan. L. Rev. 451 (2015)
- Robert E. Edmonds Prize in Corporate and Securities Law
- Certificate in Business and Commercial Law
- Transactional Law Meet, Awarded Best Draft for Seller's Asset Purchase Agreement at the 2015 Chicago Regional
- CALI Awards (top course grade): Mergers and Acquisitions, Intellectual Property, Criminal Law
- Student Tutor, Secured Transactions
- Oliver H. Hughes Memorial Scholarship Recipient
- University of Kansas, Master of Business Administration, 2015
- University of Minnesota-Duluth, B.A., Political Science, 2010
- Dallas Bar Association
- Tax Section
- Dallas Association of Young Lawyers
- DAYL Judicial Internship Committee
- DAYL Law Student Assistance Committee
- DAYL Leadership Class 2018-2019
- State Bar of Missouri
Tax Court Determines that IRS Must Obtain Written Penalty Approval under I.R.C. Section 6751(b) to Assert Penalties against Taxpayers.... [ read ]
On December 20, the Tax Court issued a supplemental opinion in Graev v. Commissioner, in which it reversed its prior position on I.R.C. Section 6751(b) and agreed with the Second Circuit's decision in Chai v. Commissioner. In Chai, the Second Circuit held that Section 6751(b)(1) requires the IRS to obtain written supervisory approval of an initial penalty determination no later than the date the IRS issues the notice of deficiency or files an answer asserting the penalty. A previous blog post discussed the Chai decision and its impact on pending Tax Court cases.
Circumventing the Nexus Requirement: Colorado Law Imposing Sales Tax Obligations on Out-of-State Retailers is Upheld... [ read ]
On December 12, the U.S. Supreme Court denied the petition for certiorari in Direct Marketing Association v. Brohl (Direct Marketing). As a result, the Tenth Circuit's earlier decision in Direct Marketing will stand. In Direct Marketing, 814 F.3d 1129 (10th Cir. Feb. 22, 2016), the Tenth Circuit upheld a Colorado law requiring out-of-state retailers with no physical presence in Colorado to either voluntarily collect sales tax or comply with substantial notice and reporting requirements. At least arguably, the Colorado statute at issue represents yet another attempt by a state to circumvent the physical presence requirement imposed by the U.S. Supreme Court on a state's ability to impose its tax collection obligations on an out-of-state entity.