Education

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LL.M. In Taxation, With High Honors, 1978

New York University School of Law

New York, New York

• New York Graduate Editor, Tax Law Review, 1977-1978
• Recipient Of Gerald L. Wallace Honor Scholarship
• Vita Taxpayer Assistance Program

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J.D., Law With Highest Honors, 1977

Louisiana State University School Of Law

Baton Rouge, Louisiana

• Executive Editor, Louisiana Law Review
• Order of Coif (Top 7%)
• Student Instructor In Law School’s First-Year Legal Research And Writing Course, 1974-1975.

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B.S., Finance and Accounting, With Highest Honors, 1974

Louisiana State University School Of Business

Baton Rouge, Louisiana

• Dean’s Honor List, Every Semester

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Career History

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Tax Partner

Law Offices of Robert Weston Nuzum, PLLC

February, 2013 to Present

Galveston, Texas

Manage and operate a solo tax law practice representing clients in tax, business and corporate matters, with an emphasis on Federal tax, international tax, and state and local tax matters.

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Tax Partner

Ryan Law, LLP

August, 2012 to January, 2013

Austin, Texas

Supervised tax associates while representing clients in Federal and state tax matters, with an emphasis on tax planning, partnership taxation, LLC and LLP tax planning, international taxation, property tax, oil and gas tax, and tax controversies and tax litigation.

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Shareholder

Baker Donelson Bearman Caldwell & Berkowitz, PC

May, 2005 to August, 2012

New Orleans, Louisiana

Partner in charge of Louisiana tax practice for 850-attorney multi-national law firm, encompassing three offices in New Orleans, Baton Rouge and Mandeville in tax matters, with an emphasis on Federal tax, international tax, partnership tax, state and local tax, and tax controversies and tax litigation.

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Partner

Law Offices of Robert W. Nuzum and Associates, LLC

March, 2003 to May, 2005

Metairie, Louisiana

Managed and operated a solo law practice with two employees and represented clients in Federal tax and state tax matters, tax controversies and tax litigation, and estate planning.

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Partner

Phelps Dunbar, LLP

January, 1990 to March, 2003

New Orleans, Louisiana

Supervised, managed and directed tax associates in active Federal tax and state and local tax practice for 200-attorney law firm with offices in London, Texas, Louisiana, Mississippi, Florida and Washington, D.C.

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Partner (1983 to 1990) and Associate (1981 to 1983)

Jones Walker, LLP

May, 1981 to January, 1990

New Orleans, Louisiana

Commenced private sector employment as an associate and then as a partner in the Tax Section, where I supervised numerous tax associates in Federal tax practice, with my emphasis on mergers, acquisitions, liquidations and distributions by corporations and LLCs, including state law tax aspects.

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Trial Attorney

Office of Chief Counsel, IRS

1978 to 1981

Washington, D.C.

Worked in the National Office of Chief Counsel, serving as a tax attorney for IRS Commissioner in Tax Litigation Division, where I tried cases and motions in the U.S. Tax Court, negotiated with Department of Justice (Tax Division) for appeals to Federal Circuit Courts of Appeal, rendered tax advices to District Counsel attorneys in Field Offices throughout the U.S., and was appointed to the Chief Counsel’s Tax Force on Tax Shelters, managed in Chicago, Illinois.

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Tax Accountant and Tax Attorney

Coopers & Lybrand, CPAs (Now PriceWaterhouseCoopers)

1978 to 1979

Washington, D.C.

Employed in the National Office, where I rendered tax and audit reviews and advices to partners, principals, tax staff and audit staff in the field offices located throughout the U.S. This was a temporary job, pending the IRS’s 1978 budget approval and subsequent funding by the U.S. Congress.

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Professional Honors & Achievements

• Texas Top Rated Lawyer - 2019-2014.
• Top Rated Lawyer, The American Lawyer, 2016, 2015 and 2014.
• Best Lawyers in America, Tax Law and Tax Litigation and Controversies, 2003 through 2013.
• Chambers, USA - America’s Leading Lawyers for Business and Corporate Mergers and Acquisitions, 2013, 2012, 2011 and 2010.
• SuperLawyers in Louisiana, 2007 through 2013.
• Top 50 Lawyers in Louisiana, SuperLawyers, 2013, 2012, 2011, 2010, 2009, 2008 and 2007.
• AV Preeminent Peer Review, Martindale-Hubble, 1983 through Present.
• Adjunct Professor of Tax Law, Tulane University Law School, 1998 through 2012.
• Member, ABA Section of Taxation, 1978 through present; Committee Memberships: Banking and Savings Institutions, Corporate Tax, Partnerships and LLCs, Affiliated & Related Corporations, Court Procedure and Practice, Foreign and International Tax, Real Estate, State and Local Tax and Teaching Taxation Committees.
• Tulane Tax Institute Planning Committee, 1993 through 2013.
• Special Appointment by ABA, Hurricane Katrina Task Force, Study Business and Tax Benefits and Incentives to Restore GO Zone, 2006 through 2009.
• Chairman, Louisiana Tax Specialization Committee, 2004, 2003, 1999 and 1998.
• Member in Good Standing, Louisiana Bar, 1977 to present.
• Member in Good Standing, Texas Bar, 2009 to present.
• Member in Good Standing, D.C. Bar, 1979 to present.
• Member in Good Standing, United States Tax Court Bar, 1978 to present.
• Member in Good Standing, United States Supreme Court Bar, 1981 to present.

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Publications

• “Trump’s Tax Returns: A Tax Lawyer’s Rebuttal”, The American Lawyer (October 4, 2016).
• “Congress Fails to Deliver its Christmas Present to GO Zone Residents and Businesses,” Daily Tax Report, pages J-1 through J-3 (January 26, 2007).
• “Louisiana Revenue Department’s Website”, published in New Orleans Bar Association’s Briefly Speaking, Fall, 2002.
• 2001 Louisiana Tax Legislation”, 62 CCH State Tax Review, pages 8-10 (December 26, 2001).
• “The New Louisiana Tax Amnesty Program: Is It The Best Thing Since Sliced Bread?”, 62 CCH State Tax Review, pages 8-13 (October 1, 2001).
• “Recent Case Explores Concept Of Tax Nexus In Louisiana”, 62 CCH State Tax Review, pages 16-21 (August 20, 2001).
• “Contract Auditors: Do They Have A Contract On You?”, published in Volume 59 CCH State Tax Review, pages 16-19 (February 23, 1998).
• “State and Local Taxation of Banks and Other Financial Institutions, Louisiana Chapter”, 1998-1999 Edition, ABA Section of Taxation.
• “Fifth Circuit Rejects Automatic Application of Credit Cycle Factor in Bardahl Formula”, published in 67 Journal of Taxation 685 (October, 1989).
• “How Does Louisiana Tax Banks and Bank Holding Companies”, 54 The LBA Banker 22 (December, 1986).
• “Louisiana Taxation of Banks, Financial Institutions and Their Holding Companies”, published in 33 Louisiana Bar Journal 237 (December, 1985).
• “Waiver of the Family Ownership Rules under Section 302(c)(2)(A)”, published in Corporate Counsel’s Annual 1985, pages 1417-1448 (Matthew Bender & Company, Inc. 1985).
• “When Will A Change To An ISO Constitute A Modification”, published in 61 Journal of Taxation 406 (December, 1984).
• “Waiver of the Family Ownership Rules Under Section 302(c)(2)(A): Retention or Reacquisition of a Prohibited Interest”, published in 11 Journal of Corporate Taxation 19 (Spring, 1984).
• “Where, Oh Where, Is the Lease Tax Due?”, published in 31 Louisiana Bar Journal 346 (April,1984) (coauthored).
• “Current Developments In Federal Taxation”, published in 31 Louisiana Bar Journal 315 (February, 1984).

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Speeches & Presentations

• “Groupon, Deal of the Day, and Living Social – Sales Tax Treatment,” presented to Bloomberg BNA Webinar (June 12, 2012) (Co-presenter).
• “Tax Evolving Concepts for Selling Goods and Services. . . ,” presented to ABA Tax Section, State and Local Taxation Committee, Washington, D.C. (May 11, 2012) (Co-presenter).
• “Wouldn’t it be Nice if States had a Common Definition of ‘Sales Price’?” presented to COST Annual Meeting, New Orleans, Louisiana (October 20, 2001) (Co-presenter).
• “Recent Developments in Louisiana Tax Procedure,” presented to Tax Executives Institute, New Orleans, Louisiana (October 27, 2011).
• “Can You Keep a Secret? Discovery and Confidentiality in State Tax Controversies,” presented to ABA Tax Section, Washington, D.C. (May 6, 2011) (Co-presenter).
• “Current Issues in State and Local Taxation,” presented to 59th Annual Tulane Tax Institute, New Orleans, Louisiana (November 3, 2010).
• “Property Taxes and Bankruptcy/Restructuring,” presented to SEATA, Little Rock, Arkansas (July 13, 2010) (Co-presenter).
• “Tax Provisions of ARRA of 2009”, presented to SEATA, Biloxi, Mississippi (June 29, 2009) (Co-presenter).
• “Louisiana Disaster Tax Relief, presented to Tax Executives Institute, Regional Meeting, New Orleans, Louisiana (April 17, 2009).
• “AARA of 2009 Tax Provisions,” presented to Baton Rouge Chamber of Commerce, Baton Rouge, Louisiana (March 3, 2009).
• “Basic Sales and Use Tax,” presented to COST, Atlanta, Georgia (January 26-28, 2009).
• “Recent Developments in Louisiana Property Taxes,” presented to Tax Executives Institute, New Orleans, Louisiana (April 18, 2008).
• “Disaster Tax Planning and Recovery – The GO Zone Act,” presented to 56th Annual Tulane Tax Institute, New Orleans, Louisiana (October 25, 2007).
• “An Introduction to New Markets Tax Credits – Federal and Louisiana,” presented to Tax Executives Institute, New Orleans, Louisiana (April 18, 2007).
• “How to Finance and Raise Equity for Resort Developments,” presented to Hotel Investment and Finance Summit, New York, New York (April 11, 2007).
• “Louisiana Tax Audits and Other Louisiana Procedural Devices,” presented to the Tax Executives Institute, New Orleans, Louisiana (March 19, 2004).
• “The Pros And Cons Of A Louisiana Tax Court – A Panel Presentation”, presented to the Louisiana State Bar Association, Section of Taxation, Annual Mardi Gras Meeting, New Orleans, Louisiana (February 19, 2004).
• “Louisiana Department of Revenue Policy Documents – What Are They And How Important Are They To Your Client?”, presented to the Tax Executives Institute, New Orleans, Louisiana (March 21, 2003).
• “2002 Louisiana State And Local Tax Update”, presented to the PriceWaterhouseCoopers’ State Tax Meeting, Houston, Texas, (October 24, 2002).
• “A Hodgepodge Of Louisiana Tax Developments”, presented to the Tax Executives Institute, New Orleans, Louisiana (March 1, 2002).
• “2001 Louisiana State and Local Tax Update”, presented to the PriceWaterhouseCoopers’ State Tax Meeting, Houston, Texas (October 18, 2001).
• “Tax Nexus In Louisiana”, presented to the Tax Executives Institute, New Orleans, Louisiana (February 9, 2001).
• “Louisiana State And Local Tax Update – The Year 2000 Has Been A Wild And Crazy Year!”, presented to the PriceWaterhouseCoopers’ State Tax Meeting, Houston, Texas (October 19, 2000).
• “A Glimpse At the Upcoming Louisiana Legislative Sessions”, presented to the Tax Executives Institute, New Orleans, Louisiana (March 31, 2000).
• “Sizzling Issues In Louisiana State And Local Taxation”, presented to the PriceWaterhouseCoopers’ State Tax Meeting, Houston, Texas (February 18, 1999).
• “Dealing With Third-Party Contract Auditors In State And Local Tax Audits”, presented to the Tax Executives Institute, New Orleans, Louisiana (January 29, 1999).
• “Contract Auditors”, presented to ABA Section of Taxation, State and Local Taxes Committee, San Antonio, Texas (January 23, 1998).
• “Louisiana Taxation of Utilities – Selected Topics”, presented to the Texas Utilities Excise Tax Association, New Orleans, Louisiana (September 15, 1997).
• “Louisiana State and Local Tax Update”, presented to the PriceWaterhouseCoopers Houston State Tax Forum, Houston, Texas (June 19, 1997).
• “Louisiana State and Local Tax Update”, presented to the PriceWaterhouseCoopers Houston State Tax Forum, Houston, Texas (April 18, 1996).
• “Resolving Disputes with the Internal Revenue Service”, presented to Tax Attorneys and Certified Public Accountants, New Orleans, Louisiana (June 8, 1990).
• “Governor Roemer’s Louisiana Tax Proposals: What Does The Future Hold?”, presented to New Orleans Chapter of the Tax Executives Institute, New Orleans, Louisiana (May 11, 1989).
• “Charitable Giving, Past, Present and Future”, presented to the Louisiana Association of School Educators, Baton Rouge, Louisiana (November 23, 1987).
• “IRS Controversies at the Appeals and Litigation Levels”, National Business Institute Seminar, presented to Tax Attorneys and Certified Public Accountants, New Orleans, Louisiana (August 22, 1986).
• “Tax Treatment of Corporations and Shareholders’ Accounting and Depreciation Changes”, presented to the Louisiana State Bar, Section of Taxation (November 16, 1984).
• “Strategies In Tax Litigation”, presented to the New Orleans Chapter of the Tax Executives Institute, New Orleans, Louisiana (September 20, 1984) (Co-presenter).
• “Corporate Tax Provisions of The Tax Reform Act of 1984”, presented to the Louisiana Society of CPAs, Shreveport Louisiana (August 24, 1984).
• “Corporate Tax Provisions of The Tax Reform Act of 1984”, presented to the Louisiana Society of CPAs, New Orleans, Louisiana (August 17, 1984).
• “Corporate Tax Provisions of The Tax Reform Act of 1984”, presented to the Louisiana Society of CPAs, Lafayette, Louisiana (August 10, 1984).
• “Selected Corporate Tax Provisions of the Tax Equity and Fiscal Responsibility Act of 1982”, presented to the New Orleans Chapter of the Tax Executives Institute, New Orleans, Louisiana (February 17, 1983).
• “Business Tax Provisions of the Tax Equity and Fiscal Responsibility Act of 1982, presented to the Louisiana State Bar Association, Section of Taxation, New Orleans, Louisiana (September 10, 1982).
• “Selected Corporate Tax Provisions of the Tax Equity and Fiscal Responsibility Act of 1982”, presented to the New Orleans Chapter, Tax Executives Institute (February 17, 1983).
• “Business Tax Provisions of the Tax Equity and Fiscal Responsibility Act of 1982”, presented to the Louisiana State Bar Association, Section of Taxation (September 10, 1982).
• Other Presentations from 1980 to 1982.

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Charitable & Civic Endeavors

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Galveston, Texas

• United Way of Galveston County, Member and VITA Volunteer, 2013 to 2018.
• University of Texas Medical Branch, The President’s Cabinet, 2014 to 2018.
• Galveston Island Humane Society, Member and Volunteer, 2013 to present.
• Galveston Historical Foundation, Member, Menard Society, 2013 to present.
• Friends of the Rosenberg Library, Member and Special Friend, 2013 to present.
• Moody Gardens, Member, 2013 to present.
• The Grand 1894 Opera Houston, Member, 2013 to present.
• Galveston Symphony Orchestra, Member and Patron, 2013 to present.
• Museum of Fine Arts, Houston, Member, 2013 to present.

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Austin, Texas

• Austin Bar Association

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New Orleans, Louisiana

• Rex “Pro Bono Publico” Foundation, 2005-Present.
• Warren Easton Charter School, Member, Board of Directors, 2006-2011; Legal Advisor, 2006-2011.
• P.A.C.E. - Program For Advanced Care of Elderly and Disimpoverished, 2010-2012.
• Archbishop Hannan’s Community Appeal, Chairman, 2008-2009.
• Make-A-Wish Foundation of Louisiana, President, 2003-2004, Vice President, 2001-2003, Treasurer, 1999-2002.
• Louisiana SPCA, Advisory Board, 2002-Present, Vice President, 1992-1993, Board Member, 1985-1999.
• Archbishop’s Community Appeal, Executive Committee, 1999-2012, Representative, 1990-2012.
• Educational Broadcasting Foundation, WLAE Channel 32, Louisiana Public Broadcasting, 2003-2010, Board Member, Legal Advisory Committee, Chairman, Back-To-The-Studio Fundraiser.
• St. Francis Xavier Catholic Church, Pastor’s Advisory Committee, 1998-2009.
• St. Francis Xavier Catholic Church, Finance Committee, 1999-2009.
• Court Appointed Special Advocate (“CASA”), 1988-2003, In The Interest Of The Harris Children, Orleans Parish Juvenile Court, State of Louisiana.*

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Significant Precedential Tax Cases Litigated

Federal Income Tax Cases

1. J. H. Rutter Rex Manufacturing Company, Inc. v. Commisioner, 853 F. 2d 1275 (5th Cir. 1988), rehearing denied (5th Cir., November 9, 1988), cert. denied, U.S. (1989) (accumulated earnings tax and procedural issues);
2. James H. Rutter v. Commisioner, 853 F. 2d 1267 (5th Cir. 1988) (reasonable compensation and procedural issues);
3. J. H. Rutter Rex Manufacturing Company, Inc. v. Commisioner, T.C. Memo. 1987-296 (June 16, 1987) (Judge Irene Scott) (accumulated earnings tax, reasonable compensation and procedural issues);
4. Hope v. United States, 803 F. 2d 816 (5th Cir. 1986) (challenge to validity of IRS regulation); and
5. Hope v. United States, 617 F. Supp. 439 (E.D. La. 1985) (challenge to validity of IRS regulation).

State Tax Cases

More than 50 Louisiana state tax cases have been litigated in the Louisiana Supreme Court, the Louisiana Courts of Appeal in the First, Fourth and Fifth Circuits, and in more than 20 Louisiana District Courts.

The most significant Louisiana state tax cases would include the following:

1. Dillard's, Inc. v. Kennedy, Louisiana Dept. of Revenue, 40 So. 3d 273 (La. 1st Circuit 2010);
2. Bridges, Louisiana Dept. of Revenue v. Higbee Company, 41 So. 3d 661 (La. 1st Circuit 2010);
3. Slaughter, Louisiana Dept. of Revenue v. Edison Chouest Offshore, Inc., 845 So. 2d 425 (La. 1st Circuit 2003);
4. BP Oil Company v. Plaquemines Parish Government, 651 So. 2d 1322 (La. Supreme Court 1994);
5. Slaughter, Louisiana Dept. of Revenue v. ARCO Chemical Company, 931 So. 2d 387 (La. 1st Circuit 2006);
6. Bridges, Louisiana Dept. of Revenue v. Lyondell Chemical Company, 938 So. 2d 786 (La. 1st Circuit 2006);
7. Morrison, Louisiana Dept. of Revenue v. Dillard Department Stores, Inc., 769 So. 2d 742 (La. 1st Circuit 2000);
8. Citizens Utilities Company v. Secretary, Louisiana Department of Revenue and Taxation, 19th Judicial District Court, East Baton Rouge Parish, Docket No. 412-524, Division "C";
9. D. H. Holmes B.R., Inc., D.H. Holmes Realty, Inc., and D.H. Holmes Credit Corporation v. Leon R. Tarver, II, Secretary, Department of Revenue and Taxation, Louisiana Board of Tax Appeals, Docket Nos., 3684, 3684, 3685;
10. Atlantic Richfield Company, ARCO Pipe Line Company, and Black Lake Pipe Line Company v. Secretary, Department of Revenue and Taxation, Louisiana Board of Tax Appeals, Docket No. 3770;
11. LGS Natural Gas Co. vs. Secretary, Department of Revenue and Taxation, Louisiana Board of Tax Appeals, Docket No. 4367;
12. Mustang Industrial Equipment Company v. Secretary, Louisiana Department of Revenue and Taxation, 19th Judicial District Court, Parish of East Baton Rouge, Docket No. 420745;
13. State of Louisiana v. Dell International, Inc., Docket No. 2004 CA 1702 (La. 1st Cir. 2006);
14. The Travelers Insurance Company v. Louisiana Tax Commission, Civil District Court, Parish of Orleans, Docket No. 95-1250; and
15. International Business Machines Corporation v. Secretary, Department of Revenue and Taxation, Louisiana Board of Tax Appeals, Docket No. 3953.