Charles J. Lavelle Chaz is a member of the Tax and Finance Practice Group. He currently is the Federal Tax Team Chair and the Insurance Industry Team Chair and is a former Tax and Employee Benefits Team Chair. He is primarily engaged in federal tax controversy work, but also has an emphasis on the formation, operation and taxation of captive insurance companies. He has resolved scores of cases with the IRS or in the courts relating to federal income, estate, gift and estate taxes, penalties and interest. Chaz also counsels clients in tax planning, particularly for captive insurance companies and their owners.
Education
B.S., Chemistry Conc., high honors, University of Notre Dame, 1972
J.D., University of Kentucky, 1975
LL.M., Taxation, New York University, 1977
Admitted to Practice
Kentucky, 1975
Courts Admitted to Practice
United States Tax Court, 1977
U.S. District Court, Western District of Kentucky, 1977
U.S. Court of Appeals for the Sixth Circuit, 1986
U.S. Court of Appeals for the Federal Circuit, 1986
U.S. Court of Federal Claims, 1986
U.S. Supreme Court, 1989
Professional Leadership
Past Chair, Vice Chair and Secretary Southeast Region IRS - Bar Liaison
Kentucky Limited Liability Company Initial Legislation Drafting Committee
Past Chair and Vice Chair, Central Regional IRS - Bar Liaison
Past Member, IRS Central Region Regional Counsel Advisory Group
Past Chair, Kentucky Bar Association Tax Section
Past Chair, Louisville Bar Association Taxation Committee
Chair, Professional Services Committee, American Bar Association Tax Section; Past Vice Chair of Personal Service Organizations; and Past Vice Chair of Closely Held Business Committee
Reported Decisions - Tax Counsel
Ocean Drilling & Exploration Company v. United States, 988 F.2d 1135 (Fed. Cir. 1993) - substantial unrelated business captive insurance
Humana Inc. and Subsidiaries v. Commissioner, 811 F.2d 247 (6th Cir., 1989) - "brother sister" captive insurance
Resolution of dozens of cases relating to federal income, estate, gift and excise taxes, penalties and interest involving the health care, insurance, natural resources, fast foods, manufacturing, equine and other industries, including definition of insurance, taxation of HMO's as insurance companies, interest computations, mitigation provisions, investment credit, tax accounting, qualification for cash basis accounting, depreciation, accumulated earnings tax, air transportation tax, depletion, fringe benefits, black lung tax, reasonable compensation, valuation, capitalization and cost segregation.
Honors and Awards
Fellow, American College of Tax Counsel
Conferee, United States Tax Court Judicial Conference (Judge's invitation only) (twice)
Listed in "The Best Lawyers in America" Taxation (Woodward/White, Inc.), since 1993
Faculty, International Center for Captive Insurance Education
Civic and Charitable Involvement
Past Chairman, Executive Committee and Director, Kentucky Chamber of Commerce
Past Vice-Chair, Executive Committee and Director, Leadership Kentucky Foundation
Past President and Director, Leadership Kentucky Alumni
Past Director, Secretary and Treasurer, KCTCS Foundation
Past Treasurer, Sergeant at Arms and Director, Downtown Louisville Rotary Club
Past Planning Committee and Participant, Kentucky Conclave on Legal Education
Past Member, Steering Committee, Kentucky Education Coalition
Visiting Committee, University of Kentucky Law School
Past Alumni Senator, University of Notre Dame Alumni Senate
Past Kentucky Bar Association Annual Convention CLE Committee Member
Past President, Director and Treasurer, University of Kentucky Law Alumni Association.
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