MICHAEL A. RAIKEN
Cherry Hill,NJ
Summary
Results driven Partner experienced in advising clients in tax law. Proficient in drafting legal documents and negotiating settlements. Poised and dedicated professional with proven ability to thrive in busy and stressful environments.
Overview
24
24
years of professional experience
1
1
Certification
Work History
Managing Member & Non-Equity Partner
Raiken Law, LLC & Adeptus Advisors, LLC
04.2023 - Current
- Developed and maintained relationships with customers and suppliers through account development.
- Accomplished multiple tasks within established timeframes.
- Reviewed and analyzed pertinent state and federal laws and legal precedents.
- Collaborated with colleagues and support staff to maximize team efficiency.
- Negotiated settlements with Federal and State Tax Agencies.
- Prepared and submitted Offers-in-Compromises to reduce taxes owed by an average of $1,000,000.
- Communicated with clients and collected information to research cases and prepare penalty relief requests to significantly reduce or eliminate them.
- Worked with clients to resolve conflicts with firm to retain services and settle error disputes.
Associate/Principal
E. Martin Davidoff, LLC & Prager Metis, CPAs, LLC
04.2019 - 04.2023
- Conducted legal research and conferred with colleagues with subject matter expertise to develop strategies and arguments in preparation for presentation of cases before Federal and State Tax Agencies.
- Filed timely responses from agencies to meet firm deadlines.
- Developed strategies to resolve tax audit and collection cases in client's best interest.
- Represented clients in civil litigation, criminal proceedings and appeals in state and federal courts.
- Analyzed legal and financial documents and identified pertinent issues for clients.
- Minimized tax liability risk exposure through careful advice on business operations and strategic plans.
- Communicated with clients and collected information to research cases and prepare settlement offers.
Tax Director
MillerMusmar CPAs and Advisors
01.2017 - 04.2019
- Supervise a 12-person tax department with oversight of all phases of compliance, controversy, planning, and projections
- Develop workpaper, return, and workflow procedures to reduce preparation and review time of individual, trust, non-profits, and business returns by 15 to 20 percent
- Conduct personnel reviews and training programs to assist staff understand their responsibilities and the complicated tax laws confronted while preparing the firms expatriate and domestic returns
- Analyze and plan complicated tax free corporate reorganizations involving foreign and domestic subsidiaries
- Cultivate client relationships with prospective and current clients increasing the services provided by the firm and its respective revenue
- Meet with clients to gain an in-depth understanding of their business activities to assert tax planning needs and deliver relevant tax planning advice
- Continually coordinate with the partners to develop and implement firm strategies and goals
- Device training and recruiting policies insuring proper personnel are in place to meet the firms changing focus to advisory services
Senior Tax Counsel
Kundra & Associates, P.C.
01.2016 - 01.2017
- Analyzed partnership, trust, and corporate documents including financial records to effectively represent individuals and entities before federal and state tax agencies
- Prepared memorandums to document and communicate facts with legal analysis of complicated tax issues
- Worked with a team of attorneys and paralegals to develop strategies minimizing tax liabilities of individuals, trusts, and various entities
- Reviewed junior attorneys' research and workpapers assist in their career development
- Trained junior attorneys and paralegals in tax law, as well as policies and procedures of the Tax Court and Government Agencies
- Advanced a system of controls and procedures for the office to ensure timely filing of documents and efficient workflow
Senior Tax Manager
Bond Beebe Accountants & Advisors
01.2015 - 01.2016
- Performed tax planning and research for complicated entity structures and transactions within the construction industry
- Analyzed contracts and business transactions to provide tax saving advice and guidance
- Discovered a contract drafting error in time to avoid the accelerated recognition of approximately $4,000,000 in ordinary income
- Aided in the selection of entities and business transactions regarding tax and legal consequences
- Reviewed tax returns of partnerships, corporations, and individuals containing both domestic and foreign transactions and affiliates
- Prepared individual, corporate, and partnership federal and multi-state returns
- Recommended tax strategies for domestic and foreign transactions, business formation, succession, and liquidation
Senior Attorney
Office of Chief Counsel – Internal Revenue Service
01.2009 - 01.2015
- Represented the IRS in civil tax matters with complete oversight and control administrative files, pleadings, trial planning, motions, discovery, legal research, and courtroom appearances
- Supervised staff attorneys while preparing for complicated Tax Court cases involving civil fraud and novel tax issues
- Successfully argued the in-perpetuity requirement of conservation easements
- Instrumental in presenting a legal issue about an illusory Crummy Powers and its effect on the annual exclusion
- Litigated before the U.S
- Tax Court and utilized valuation and environmental expert witnesses, cross-examined witnesses, and wrote post-trial briefs
- Wrote and argued Motions for Summary Judgments before the U.S
- Tax Court for collection due process cases, estate and gift taxes, and civil fraud
- Identified, presented, and coordinated tax issues with the Office of Chief Counsel's National Office and issue management teams saving the government millions of dollars in tax revenue
- Negotiated settlements for over 300 Tax Court controversies regarding partnerships, corporations, individuals, estates, and trusts
- Reviewed tax returns, revenue agent work papers, and reports to recommend the assertion of the civil and criminal fraud penalty
- Provided advice and explained the legal requirements to revenue agents and the Department of Justice for administrative summonses, transferee liability, and nominee, alter ego, or successor in interest liens and levies
- Prepared and presented educational material to revenue agents and other attorneys on the utilization of the indirect methods for recreating income including bank deposit analysis and source and application of funds
- Assisted in the drafting of procedures to streamline civil and criminal joint investigations and referrals
- Reviewed offshore voluntary disclosure initiative submissions for accuracy and proper determinations made by revenue agents
- Coordinated the examination of a complicated real estate transaction between U.S
- And international high-net-worth individuals that utilized an intricate web of foreign and domestic trusts and entities
Revenue Agent
Internal Revenue Service
01.2001 - 01.2006
- Examined over 300 individual, partnership, informational, estate and gift, and corporate federal income tax returns
- Wrote and presented reports outlining proposed adjustments and explained the applicable law and regulations to taxpayers and their representatives resulting in full concessions
- Made referrals to IRS criminal investigation division that were presented to the U.S
- Department of Justice for prosecution
- Discovered the use of a mixed security instrument being marketed in the U.S
- And Canada used to evade taxes in both countries
Education
J.D. - Law
Ohio Northern University
Ada, OhioBachelor of Science - Accounting
Bradley University
Peoria, ILSkills
- Strategic planning
- Clear communication
- Business development
- Conflict resolution
- Decision-making
- Customer service
- Complex Problem-solving
- Effective Negotiation
Accomplishments
- Documented and resolved complex tax issues and client conflicts which led to significant tax savings and penalty relief.
Certification
- Bar Admission/License - Florida and New Jersey State Bar Association.
- Certified Public Accountant (CPA) - American Institute of Certified Public Accountants (AICPA).
- American Bar Association Member.
Work Availability
monday
tuesday
wednesday
thursday
friday
saturday
sunday
morning
afternoon
evening
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Timeline
Managing Member & Non-Equity Partner
Raiken Law, LLC & Adeptus Advisors, LLC
04.2023 - Current
Associate/Principal
E. Martin Davidoff, LLC & Prager Metis, CPAs, LLC
04.2019 - 04.2023
Tax Director
MillerMusmar CPAs and Advisors
01.2017 - 04.2019
Senior Tax Counsel
Kundra & Associates, P.C.
01.2016 - 01.2017
Senior Tax Manager
Bond Beebe Accountants & Advisors
01.2015 - 01.2016
Senior Attorney
Office of Chief Counsel – Internal Revenue Service
01.2009 - 01.2015
Revenue Agent
Internal Revenue Service
01.2001 - 01.2006
- Bar Admission/License - Florida and New Jersey State Bar Association.
- Certified Public Accountant (CPA) - American Institute of Certified Public Accountants (AICPA).
- American Bar Association Member.
J.D. - Law
Ohio Northern University
Bachelor of Science - Accounting
Bradley University
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