Practices
Tax
The bedrock of Berry Moorman's excellent reputation was founded in tax law, starting with Raymond H. Berry, a renowned estate tax lawyer, who founded our Firm to represent Horace and John Dodge in recovering taxes on the profit from the sale of their shares of Ford Motor Company. Through the years, we have been involved in a number of noteworthy tax matters, including our successful representation of Mr. Clarence P. Chamberlin in the first preferred stock bailout case, which resulted in the adoption of Section 306 of the Internal Revenue Code; our representation of the American Automobile Association before the U.S. Supreme Court to challenge the IRS's taxation of subscription payments in the year received; and our role as appraiser of the shares of Hudson Motor Car Co. in connection with that company's merger into American Motors Corporation. More recently, we obtained one of the first favorable IRS rulings that authorized the tax-free distribution of stock of a subsidiary under Section 355 of the Internal Revenue Code for the business purpose of spinning off a subsidiary with non-risky operations from a parent with operations carrying substantial risk of liability exposure.
Today, we continue that tradition of skillful tax counsel to individuals and businesses. We regularly provide assistance in tax matters involving structuring the purchase or sale of businesses, tax-free reorganizations and liquidations, tax deferred exchanges, choice of entity matters, employee benefits and executive compensation. We assist individuals in a variety of tax matters including audits, private letter rulings, income and estate tax returns, and tax litigation. We have formed and consult with a number of private charitable corporations and private charitable foundations on tax matters.
We take pride in our ongoing efforts to maintain cutting edge knowledge in respect to pertinent rulings and new or proposed legislation affecting our clients' tax planning objectives. We continuously strive to maintain this edge so our clients receive the benefits of such law at the earliest opportunity.