ABA Tax Times Interviews Jonathan Black in Latest Issue

ABA Tax Times

Jonathan Black was interviewed for People in Tax section of ABA Tax Times Fall 2023 issue published on January 14, 2023.

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ATT Editor’s Note: Jonathan R. Black is an Associate with Caplin & Drysdale in the Tax Disputes & Tax Litigation and Complex Litigation practice groups. Prior to private practice, Mr. Black served for over five years as an attorney with the Office of Chief Counsel for the Internal Revenue Service, where he defended the IRS in Tax Court, drafted regulations and other published guidance, and advised the IRS and the Department of Justice on a myriad of legal issues. He also provided IRS attorneys training on administrative law and legal ethics. In addition to his near decade of experience in tax law and litigation, Mr. Black has prior careers in property development, procurement, and analytics.

Jonathan was interviewed by ABA Tax Times’ Interview Editor and Administrative Practice Committee Publication Liaison Deanne Morton, Managing Director with Andersen Tax LLC who specializes in Tax Controversy.

DM: Hi Jonathan! We met briefly at the Administrative Practice Committee dinner during the ABA Tax Section’s Midyear Meeting in San Diego in February. We did not have much time to chat then so I am pleased to be able to interview you and learn more about your background and tax litigation practice. If you would not mind, can you first share where you grew up and some details about your childhood?

JB: Sure! My early childhood was mainly spent in a rural suburb of Boston. We had so much space, we could not see our neighbor’s house from our house. I have two siblings who were basically the only people I spent time with during those initial years. We swam in the lakes, skied in the backyard, and ran around and caught critters like insects and salamanders. My father worked in academia and during my adolescent years, he accepted a position in Oregon, which meant my family moved across the country to the West Coast. I then attended the University of Oregon for my undergraduate degree.

DM: What was your major in college and did you go directly to work after completing your undergraduate program? Tell us more about your path toward law school.

JB: At the University of Oregon, I majored in Business, with a minor in Chinese (Mandarin). I completed my undergraduate degree in three and a half years, then spent about a year working as an analyst at a semiconductor company in the U.S. I learned a lot about spreadsheets and Excel in this position, but not very much about semiconductors. However, I knew I wanted to go to China so during this time I applied to a Chinese University for post-baccalaureate studies. I then spent about four years in China, between completing my studies and work, and it was during this time that I decided I wanted to go to law school. While in China, I worked as an agent for China Southern Rail, among other things, and I assisted them in bidding on a U.S. heavy rail contract to sell their trains into the U.S. While this attempted deal may not have ultimately resulted in a completed transaction, the work required me to study various applicable statutes, which I found interesting and ultimately inspired me to come back to the U.S. for law school.

DM: What did you think you would do with a law degree? And when did the interest in tax emerge?

JB: Initially, I thought I would do international business transactions and after my 1L year I went back to China and worked in a Chinese law firm. However, I quickly realized that there were very limited opportunities in international business transactions and that the type of work I would be able to do in China did not measure up to my expectations. At some point in my 2L year, I took a tax class, and something just really clicked for me. After my 2L year, I clerked in the bankruptcy court but I had a strong interest in tax at this point and I applied for the externship with the IRS Chief Counsel Honors Program. I was accepted into that program as a 3L law student and from there I convinced them to hire me after law school.

DM: Tell us about your experience while working at IRS Chief Counsel. Is there anyone that you would like to recognize for helping to make that experience particularly positive?

JB: Chief Counsel was a great experience and I worked in the IRS National Office in Washington, D.C., in the area of Procedure and Administration. During my time there, I got to work with a ton of smart people who know their subject matter well and are committed to getting to the right answer. It was an excellent place to learn without the private practice pressure of trying to minimize time spent because it is not economical for a private client to pay for the work that needs to be done. There are so many good people in Chief Counsel that it is impossible to recognize them all, but I can give special commendation to Drita Tonuzi, who was the Associate Chief Counsel (Procedure & Administration) when I started there and later became Deputy Chief Counsel of Operations. Drita is well-known for legal guidance and support in the area of Procedure and Administration.

To view the interview in its entirety, please click on the PDF in the Related Materials below or visit the ABA’s website.


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