Professional Experience - Thomas C. Morrison

• Private practice (Helena, Montana) 1990-present

• District Counsel - I.R.S. (Helena, Montana) 1985-1989

• District Counsel - I.R.S. (Washington, D.C.) 1980-1985

• Assistant District Counsel - I.R.S. (Washington, D.C.) 1973-1980

• Trial Attorney - I.R.S. (District Counsel's Office, Washington, D.C.) 1967-1973

• Assistant Staff Judge Advocate (Army, JAGC) 1963-1966

During his career as a tax lawyer, Mr. Morrison has been directly responsible for initiating and defending hundreds of tax cases before the United States Tax Court and related judicial tax proceedings before the United States District Courts, the Montana District Courts, the United States Appeals Courts, the Montana District Courts and the Montana Supreme Court and the U.S. Supreme Court.

As an I.R.S. attorney, Mr. Morrison provided legal advice to I.R.S. District Directors on substantive tax matters, collection matters, and criminal tax matters. He worked closely with I.R.S. audit personnel (revenue agents and tax auditors), I.R.S. collection officials (revenue officers and special procedures personnel), I.R.S. criminal investigators, and I.R.S. technical personnel in Washington, D.C. During his 22 years with the I.R.S., Mr. Morrison acquired an important understanding of how I.R.S. personnel think and how they analyze and resolve tax matters. He understands the mechanics of tax investigations and tax audits; I.R.S. summons procedures; the administrative dispute resolution process (tax appeals); methods for acquiring information from the I.R.S. (Freedom of Information Act requests); procedures for obtaining technical advice and ruling requests; methods for dealing with tax payment problems (installment payment plans and offers in compromise), tax liens, and levies; the nature of criminal investigations and trials, and the formal adjudication process.

Professional Activities - Thomas C. Morrison

• co-chair of the Business, Estates, Trust, Taxation & Real Property Committee of the Montana Bar Association

• member of the Tax Section of the American Bar Association

• member of the District of Columbia Bar Association

• member of the Iowa Bar Association

• member of the Taxation Section of the Federal Bar Association

• former chairman of the Taxation Section, Federal Bar Association, 1984-1985

• founder of the F.B.A. Annual Tax Law Conference