Charles M. Ruchelman is a member in Caplin & Drysdale's Washington, D.C. office, where he specializes in tax litigation and controversies with the Internal Revenue Service and other tax authorities. Mr. Ruchelman also represents clients in general tax matters.
Before joining Caplin & Drysdale, Mr. Ruchelman was a Trial Attorney with the U.S. Department of Justice, Tax Division, an Attorney with the Internal Revenue Service, Office of Chief Counsel, and an associate in the Washington, D.C. office of an international law firm headquartered in New York City.
Mr. Ruchelman's practice focuses on representing clients before and against the IRS and other tax authorities involving substantive tax issues, promoter penalty and list maintenance issues, summons enforcement actions, and anti-money laundering examinations. Also, Mr. Ruchelman has assisted clients in obtaining favorable private letter rulings from the Internal Revenue Service.
While at the Department of Justice, Mr. Ruchelman litigated tax cases in the federal district courts and the U.S. Court of Federal Claims. For his work representing the government in extended trials involving the IRS's attack on leveraged corporate-owned life insurance as a tax shelter, Mr. Ruchelman received the Attorney General's Distinguished Service Award.
Mr. Ruchelman's litigation experience covers a wide variety of substantive tax matters in the U.S. Tax Court, the U.S. Court of Federal Claims, and various U.S. district courts. A sample of Mr. Ruchelman's cases which were resolved by judicial decision include:
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United States v. BDO Seidman LLP, 2004 WL 1470034 (N.D. Ill, June 28, 2004) (promoter penalty examination/privilege issues)
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NovaCare, Inc. v. United States, 52 Fed. Cl. 165 (2002) (corporate merger and reorganization)
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Cook v. United States, 52 Fed. Cl. 62 (2002) (trust fund penalty for employment taxes)
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Four Star Oil & Gas Co. v. United States, 51 Fed. Cl. 110 (2001) (restricted interest)
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American Elec. Power, Inc. v. United States, 136 F.Supp.2d 762 (S.D. Ohio 2001) (broad-based corporate owned life insurance)
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In re CM Holdings, Inc., 254 B.R. 578 (D. Del. 2000) (broad-based corporate owned life insurance)
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Soo Line R.R. Co. v. United States, 44 Fed. Cl. 760 (1999) (restricted interest)
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Estate of Newman v. Commissioner, 111 T.C. 81 (1999) (estate tax)
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Adams v. Commissioner, T.C. Memo. 1997-63, 73 T.C.M. (CCH) 1913 (1997) (business income and expenses)
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North West Life Assurance Co. of Canada v. Commissioner, 107 T.C. 363 (1996) (international tax and treaty issues)
Mr. Ruchelman is the current Chairman of the Tax Audits and Litigation Committee for the Tax Section of the D.C. Bar. This committee presents monthly panel discussions on hot topics in the tax audits and litigation arena and frequently interacts with IRS and DOJ tax officials. He is also an active member of the American Bar Association Section of Taxation and the Court of Federal Claims Bar Association. He currently serves as the ABA Chairman of the Tax Refund Litigation Subcommittee.