Jeffrey M. Wong, Attorney
Oregon State Bar, 1984 to present; Oregon State Bar, 1984 to present; US Tax Court, 1984 to present; US District Court for Oregon, 1999 to present; US Claims Court, 2021 to present. Oregon State Bar Taxation Section Executive Committee, 2007-2012; Oregon State Bar Taxation Subcommittee on State Legislation and Regulations, 2008-2012; Chairperson, Oregon State Bar Taxation Awards Subcommittee, 2008 to 2010; Oregon Tax Court advisory committee for the Oregon Judicial Department's eCourt initiative, 2010.
Reed College, BA, psychology, 1978; Commendation for academic excellence, 1978.
University of Oregon Law School, JD, 1984.
Solo Legal Practice, June, 2009 through present.
Private practice focusing on tax controversy, bankruptcy, and debtor representation. I have handled a broad range of tax controversy issues, including examinations for unreported income, prohibited transactions, passive losses, flow through entity adjustments, deduction substantiation, tax shelters, and worker classification, as well as collection controversies of all sizes with both federal and state liabilities. I have served as an expert witness for both plaintiffs and defendants and the Oregon Professional Liability Fund over a dozen times during my years in private practice.
Greene & Markley PC. August, 1998 through May, 2009.
Private practice focusing on tax controversy, bankruptcy, and debtor representation. Elected a shareholder in January, 2005. Developed and managed a tax and bankruptcy department of four attorneys and two paralegals.
Special Assistant US Attorney, District of Oregon, and trial attorney for Chief Counsel for the Internal Revenue Service, 1988 to 1998. Duties included:
Primary advisor to the Oregon IRS Special Procedures Function and Collection Division Field Branch from 1991 to 1998. Provided oral and written advice on virtually all aspects of bankruptcy and field collection administration. Review, as required by the Internal Revenue Manual, of extraordinary collection actions.
Development and litigation of tax-related cases before the US Bankruptcy Court and income tax controversies before the US Tax Court. Primary bankruptcy litigator for the IRS in Oregon from 1991 to 1998; handled most bankruptcy controversies involving large tax liabilities or novel issues.
Coordination of investigative efforts of the Examination and Collection Divisions in large dollar unreported income and concealed asset cases involving multiple bank account and entity schemes. Civilly prosecuted several of these cases.
Referral and coordination of tax cases before the US District Court with the Department of Justice.
"Toti Case" Coordinator for the Western Region (13 states) from 1996 to 1998. Review of all cases involving the assertion of tax nondischargeability under the attempt to evade or defeat tax exception to discharge of 11 U.S.C. § 523(a)(1)(C).
Instructed Chief Counsel attorneys, IRS Revenue Officers and Revenue Agents, and employees of other governmental agencies on a variety of tax and non-tax issues in Treasury sponsored educational events.
Disclosure Coordinator for Portland District Counsel. Provided advice to the IRS Disclosure Officer and other IRS personnel on the tax confidentiality laws.
Trial attorney, Office of Chief Counsel for the Internal Revenue Service, Laguna Niguel, California District, 1984 to 1988. Duties included:
Development and litigation of individual and corporate income tax cases before the US Tax Court. Responsible for numerous abusive tax shelter investigations and enforcement actions; Coordinator for shelter investments involving electricity producing windmills.
Primary lien, seizure, and bankruptcy advisor to the Laguna Niguel Special Procedures Function and Field Collection Branch, 1987-1988.
Acting Assistant District Counsel, 1987-1988. Trained and managed six attorneys.
Awards and Recognition:
Best Lawyers' 2014-15 Portland, OR Litigation and Controversy "Tax Lawyer of the Year."
Selected for inclusion in Best Lawyers in America, 2010 through the present year; First Tier Ranking in Best Law Firms for tax law by US News and Best Lawyers, 2012 through the present year.
Selected as one of the 2013 Top Rated Lawyers in Corporate Restructuring and Bankruptcy by American Lawyer Media and Martindale-Hubbell.
Martindale-Hubbell "AV" rated, 1999 to the present year.
Selected for inclusion in Oregon Super Lawyers, 2012 through the present year, in the areas of bankruptcy and debtor-creditor law.
Selected by the Young Tax Lawyers Subcommittee of the Oregon State Bar's Taxation Section as the inaugural recipient of the Subcommittee's new Mentor of the Year Award in November 2010.
IRS Chief Counsel Manager Awards: 1985, 1986, 1987, 1989, 1990, 1993, 1994, 1995, 1996. Western Region Award for Excellence in General Litigation, 1991.
Published Bankruptcy Decisions:
In re Moore, 200 B.R. 687 (Bankr. D. Or. 1996) IRS right to offset income tax refunds.
In re Goude, 201 B.R. 275 (Bankr. D. Or. 1996). Unavailability of super-discharge in unfeasible Chapter 13 cases.
In re Silver Eagle Company, 262 B.R. 534 (Bankr. D. Or. 2001). IRS right to offset refunds against non-pecuniary loss penalties that are subject to subordination in Chapter 7 cases.
Published Tax Decisions:
Delta Logistics, Inc. vs. Oregon Employment Department, 279 Ore. App. 498 (2016), 361 Or 821 (2017), worker classification and liability for state unemployment tax with motor carriers and owner-operators.
Van Eck v. Commissioner, US Tax Court No. 8666-92, Sum. Op. 1995 Unreported income case involving multiple bank account scheme.
85 Gorgonio Wind Generating Co. v. Commissioner, Tax Court Memo 1994-544 Placement in service of electricity producing windmills in tax shelter.
TJE Enterprises v. Commissioner, 101 Tax Court 39 (1993) Definition of "ordinary and necessary" with business deductions.
Hoffman et al v. Commissioner, Tax Court Memo 1989-154 Income realized by promoters of abusive tax shelter.
United States v. International Dynergy, Inc., Dist. Ct., C.D. Cal., 1986-1988 Jeopardy assessment, seizure, and injunctive actions against promoters of abusive tax shelter involving electricity producing windmills.
Hello, I'm Alexis Weyers!
I am a 2006 summa cum laude economics graduate from the College of William & Mary. I received my law degree from the University of Virginia School of Law in 2013. I began my professional career as a consultant in IBM’s public sector consulting division. I later transitioned to a tax advisor position in Boston for a closely-held holding company, until I decided to obtain a law degree.
During law school, I was a member of the editorial board for the Virginia Tax Review. I interned at the U.S. District Court for the Northern District of New York and at the Legal Aid Justice Center in Charlottesville, Virginia, where I also served as an Access to Justice Fellow and was a member of the Litigation and Housing Law clinic. After receiving my law degree, I served for one year as a clerk for the Virginia Beach Circuit Court, and later taught legal research and writing as a C.V. Starr Lecturer at the Peking University School of Transnational Law in Shenzhen, China. I settled in Portland after returning from China in 2015, and knew I did not want to pursue a conventional legal career with a large firm. I placed my law license in inactive status and worked for my first year in Portland as the Operations Director at the Children’s Cancer Therapy Development Institute in Beaverton.
In 2017, I applied for licensing in Oregon and was required to complete the Bar's mandatory mentoring program. The Bar assigned Jeff as my mentor. We got along well, and at the end of the one-year program, I accepted Jeff’s offer of employment as his office manager and assistant to get a feel for his practice. I re-activated my law license in 2018 and began working for Jeff as an associate attorney. I still manage the office, and apply both my accounting and legal skills and training for our clients.
Over the five years I have worked with Jeff, I’ve obtained experience in a broad range of federal and State tax audit and collection controversies for clients ranging from wage earners to entreprenuers with large, complex businesses. We succeeded with several bankruptcy cases and numerous offers in compromise, and represented many clients in income, excise, and employment tax audits. Together, we offer clients Jeff’s expertise and my lower billing rate with the simpler cases and issues.
I'm a member of the Oregon State Bar, an inactive member of the Virginia Bar, the US District Court for Oregon, the US Tax Court, and the US Claims Court.