Michael Stonik

I operate in the multibillion-dollar carbon sequestration, clean fuels, and electricity market. I work on planning, directing, and coordinating engineering activities, actionable events, milestones, and programmatic issues under review, including deadlines and time frames for completion. I developed a system for tracking LCAs, and a SharePoint site for the LCAs’ retention. I coach and mentor team members by sharing knowledge and technical expertise, including audit techniques and experience in areas of issue specialization. I created pages for the virtual library for carbon capture, clean fuels, and clean hydrogen. I provide leadership to the PN's team of engineer SMEs on a regular and recurring basis.

I monitor and report on the work progress, and coordinate the preparation, presentation, and communication to appropriate internal and external stakeholders. I provide advanced engineering feedback, technical expertise, and recommendations to multiple stakeholders, and senior-level audiences. I make contacts with employees at all IRS levels, other government agencies, and external stakeholders, including senior tax personnel, attorneys, accountants, tax advisors, professional organizations, and the public. I maintain program and administrative reference materials, project files, and relevant background documents, and make available policies, procedures, and written instructions; I maintain current knowledge to answer questions from team members on procedures, policies, directives, and other guidance. I prepare reports, maintain records of work accomplishments and administrative information, and coordinate the preparation, presentation, and communication of work-related information.

I represent the team in dealings with the supervisor or manager for the purpose of obtaining resources and securing needed decisions from management. I facilitated the acquisition of the pertinent International Organization for Standardization’s (ISO) publications incorporated in the Internal Revenue Code (IRC). I lead the team in assessing its strength and exploring alternatives in determining what improvements can be made in work methods, processes, and procedures to carry out projects to completion. I championed the issuance of the Section 45Q procedural notice. I lead the exploration and evaluation of new theories, and provide advice on new technologies and methods. I researched carbon oxide chemistry in application to the carbon capture and sequestration credit. I developed a concept of multiple utilizations of carbon oxide streams. I inform management about the work progress, potentially controversial matters, new or emerging issues, or issues with far-reaching implications beyond the scope of an individual project, and provide recommendations for managing unprecedented conditions, resolving critical problems, and/or developing, testing, and implementing new methods.

My work products affect various business units, senior-level management, Appeals and Counsel personnel throughout the IRS, and the development of major aspects of service-wide tax compliance programs.

I possess expert knowledge of the IRC, treasury regulations, rulings, court decisions, and agency policies, develop and deliver training to the larger LB&I community, and execute significant projects representing major areas of LB&I’s operating programs. I use my analytical skills and achieve resolutions by consistently applying statutes and regulations, all applied to the facts and circumstances of each case. I apply lessons gleaned from resolutions in previous cases. I lead major projects that require analysis and the use of evaluative qualitative and quantitative methods. I work on complex projects, guidance, and studies that are broad in scope and magnitude. I have prepared training materials for, and led, conferences with Compliance, Counsel, taxpayers, and expert witnesses. I used my special ability and a highly advanced knowledge of engineering, valuation principles, tax law, and industry practices to determine the applicability and reasonableness of the facts and circumstances presented in support of tax positions. I work on cases with a wide variety of unusually complex, difficult valuation, technical, and legal tax issues of significance. I have expert knowledge of operations and case procedures, computer audit, and statistical sampling techniques to provide technical assistance in the identification, development, and resolution of issues.

I advocated for issues before Appeals and Fast Track officers. I have worked closely with the Treasury, Counsel, SBSE, Appeals, Office of Professional Responsibility, Abusive Transactions, as well as LB&I exam teams. I assisted Counsel in the preparation of a case going to the Tax Court and in the development of regulations, notices, and other guidance materials. As an example, I explained the technicalities involved in ethanol production that clearly showed the taxpayer was not entitled to an agricultural chemicals security credit because it was producing a fuel additive. As a result, Counsel was well prepared to counter the taxpayer's position.

I worked with TF&P on creating new and revising existing tax forms and instructions. Also, I worked with the Submission Processing Development teams on creating new and maintaining existing business rules for tax forms and schedules. Also, I work routinely with sister agencies like DOE, DOA, FAA, DOT, EPA, and other departments on projects with joint jurisdiction. I am a member of an interagency team that developed modeling principles for clean aviation fuel, currently used nationally by the fuel producers.

In recognition of my role and success, I received stellar annual appraisals, Special Act, and Performance awards.

Since 2012, I have served multiple tenures as a collateral SME at the Business Credits PN, where I have been providing leadership and transferring engineering knowledge and experience to revenue agents and other specialists across LB&I and SBSE in this position. I always keep my focus on people and take a leadership position to have issues resolved and ensure that all internal and external customers are satisfied. RAs always praise my work after the case ends. I leveraged my technical experience reviewing cases to assess the credibility of taxpayers’ positions, and I advised colleagues on “tactical” angles of approaching complex engineering issues. As an example, I consulted my PN customers on efficient ways of approaching cases, involving 'pre-packaged' research studies by revealing patterns in substandard claims. I advised my IPN customers to seek a reasoned resolution in the cases where the case facts allowed them to make an alternative, credible estimate of the credit. Although most of these cases were resolved at the exam level, a few had to be resolved in Appeals or Fast Track. I directed my customers in developing their cases for alternative resolutions to achieve sustainable arguments, based on case facts and governing law.

I provided expertise to RAs and engineers confronted, in their cases, with unprecedented conditions, helped them resolve critical problems, and advised them in developing, testing, and implementing new methods they could use in current and future cases. I ensured the technical and theoretical soundness of the work because of the technical and interpersonal complexities of engineering issues for the service, and continuous efforts to arrive at appropriate solutions to resolve complex engineering and valuation issues.

I assisted my customers in writing quality Issue Document Requests (IDRs). As an example, I advise RA to communicate with taxpayers before drafting the IDR, agree on terminology that taxpayers would understand, and figure out what professional terminology taxpayers are accustomed to in their respective environments. Draft IDRs must be discussed with taxpayers before issuance, and taxpayers’ input must be considered. I helped RAs formulate questions with precision and limit them to a number manageable by taxpayers, so no follow-up would be necessary. This way, RAs were able to receive adequate responses, and to proceed along their case timelines.

I always look for a taxpayer's input in audit planning and process. I review evidence gathered by the Compliance team and presented by taxpayers, and weigh such evidence in accordance with my engineering experience, case law, statutes, and regulations. As an example, based on TP’s facts, I corrected an RA who disallowed research supply expenses because they were deducted as cost of goods sold, although they were clearly used for research. I explained the case facts, the Section 174 regulation, and the related revenue ruling to the RA, and demonstrated to her that the supplies were not part of the manufacturing inventory, and that the deduction was compliant with Section 174. I explained that her arguments under the UC case would not be persuasive because of dissimilar case facts, and that her argument was not supported by legal authority. The RA rectified her position and reached an agreed resolution with the TP. As another example, in a number of cases, I advised RAs to identify reasonable taxpayers' estimates and apply them in Fast Track resolution in the cases. In these cases, the RAs had reasonable confidence that research and experimentation had occurred, but at the same time, could not quantify them for an alternative estimate.

In addition to consulting on credit-related cases, I actively participate in the PN’s sub-group developing Issue Snapshots, and other guidance and training materials. The examples are snapshots concerning credit adjustments for acquisitions, and feasibility studies.

I conducted CENTRA presentations as a subject matter expert. For example, I prepared and presented a presentation on report writing to support the examination of the research credit issue.

I identified issues in financial statements, tax returns, claims, studies, and other documentation. I collected and analyzed information, established patterns, and made fact-based decisions. I used statistical approaches while working with large populations of data and recurring events. In large cases, where the exam was confronted with massive volumes of accounting data, I requested the services of Computer Audit Specialists (CAS) to conduct efficient data extraction, compilation, and sorting, and to perform statistical sampling. This approach facilitated an efficient exam that saved the IRS’s resources. Additionally, it reduced the administrative burden on taxpayers and allowed both sides to exercise a concentrated approach. I also used CAS to assist with the development of the exam's arguments against an inappropriate use of attribute sampling. When taxpayers became aware that their sampling was not in accordance with the Revenue Procedures, they were more inclined to discuss case facts instead of the sampling projections. I employ statistical methods while working on research study projects, and I perform statistical analysis of tax data.

I always give special weight to the determination made by counsel. As an example, I requested counsel’s assistance in the funded research issue. Counsel determined that the Taxpayer’s position could be sustained because of the technicalities of its contractual arrangements, despite the exam’s valid arguments. I dropped the issue from the exam plan under the advice, and concentrated on the other regulatory credit tests.

I researched various sources, from the Internet to individual interviews with experts. I provided guidance to fellow engineers on how to access inter-agency resources for case development. In a case where an Architectural & Engineering (A&E) firm claimed a research credit for a number of projects, via an Internet search, I established that the projects were developed by different third-party architects. The A&E firm only served as a general contractor; hence, it was not involved with the projects' research and development.

I applied my analytical skills when I worked on a case with controversy. I considered potential hazards, calculated the impact on tax, and proposed fact-based resolution positions to exam teams. In a research credit case, I proposed applying a heavier weight to employees’ time-tracking records in the calculation of Qualified Research Expenses (QREs) to prepare an alternative estimate, and the taxpayer agreed. I provide leadership, consultation, and advisory services if exam cases are ready for appeals, fast track (FT), or other alternative resolutions. I prepared a presentation for the FT officer, explaining why the government would agree to a certain adjustment amount, based on the case facts and employees' testimonies. The amount in the presentation became a basis for the alternative resolution. I performed ongoing risk analysis in each case while identifying issues for the exam. I revised the risk analysis regularly as new facts and circumstances were revealed. I adjusted plans and approaches in real time to maximize the efficient use of resources, minimize the burden on taxpayers, and aid taxpayers in achieving tax compliance. I considered the needs and objectives of all team members, their respective managers, and taxpayers' positions.

In a case involving a research and experimentation credit claim, I was confronted with a challenge regarding an unsubstantiated estimate of the claimed qualified wages made by an industrial manufacturer. Instead of arguing the substantiation requirement, I applied my knowledge of the industry and engineering to determine reasonable and high-risk elements in the estimate. Through communication with the taxpayer, we agreed on adjusting the high-risk elements. In another case, I evaluated the risk of the taxpayer’s position against the code and regulatory requirements, and weighed that against the potential tax effect of the research credit claim. As a result, I limited the examination to the defendable issue of using only reasonable compensation for the corporate officers in the calculation of qualified research wages. The taxpayer appreciated the reasoning and agreed to the adjustment.

While acting as a team manager, I reviewed and emphasized the importance of the initial and ongoing risk analysis with my engineers. This was important because additional case facts learned during the course of a case provide opportunities to change the case strategy, based on materiality, and compliance considerations. Certain issues could be given a lower weight, allowing for concentration on big items and facilitating case resolution.

I effectively and clearly interpret and communicate regulations, technical specifications, and contractual requirements with the general public, legal personnel, legislators, and administrators. I provide professional skills and necessary guidance to peers, including specialists, revenue agents, and IRS attorneys. I work well with others, build teamwork, help others, and place a special emphasis on communication. I consult cases relating to IRC § 41 for revenue agents who did not have engineers assigned to their cases. I investigate, review compliance, communicate with TPs and team members to resolve engineering issues, and elevate to Appeals or adjudication when required. I work routinely as a team member on CIC, CMO, CAP, and campaigns' cases, developing and resolving tax issues. I explain guidelines, including broad policy statements, the IRM, Congressional committee reports, interagency directives, the IRS policy statements, and reference material that is pertinent to the subject matter and, many times, are ambiguous and express conflicting, or incompatible, goals and objectives. I offer extensive interpretation because of changes in the law, innovations in engineering, valuation methodology, and professional norms. I develop new methodologies or approaches to produce appropriate results. For example, I developed a limited issue scope approach in the R&E credit cases, where appropriate. My colleagues recognize me as a technical authority in developing and revising case approaches, and applying the governing policies for the use of other specialists and agents. I provide technical expertise to non-technical, and legal personnel. I review current law to remain up to date with all regulations. I provide professional skills and necessary guidance to peers, revenue agents, and IRS attorneys. I assisted an Estate & Gift (E&G) Counsel on a case involving pesticide contamination at a historic landmark property. In that case, the taxpayer claimed a large deduction on the contribution of the property. I performed a valuation of the property and the cost of remediation of exotic pesticide contamination. As a result, I showed that the property value was greatly inflated.

I analyze valuations of intellectual property and other intangible assets, including capitalization, royalties, and IP transfers. I conducted a study of the value of a patent transferred by a major manufacturer to a university, which was claimed as a charitable contribution. As a result, the exam team was able to demonstrate to the taxpayer that the patent's value was zero. I also examine depletion, abandonment, write-offs, domestic production deduction, and research credit. I am experienced in capitalization vs. Deduction issues in generating and distributive industries, including power, telecommunications, and pipelines. I support international issues, such as intercompany transactions, Subpart F income exclusion, and transfer pricing issues. I worked on the first engineering issue in the nation relating to the Subpart F income exclusion, based on a claim of substantial contribution to manufacturing. In this case, my engineering knowledge allowed me to create a study of manufacturing functions, which enabled the exam team to identify areas of potential noncompliance.

In the environmental realm, I develop issues associated with brownfields redevelopment, environmental remediation expenses, environmental contract expenses, depreciation and capitalization of environmental remediation equipment and property/land improvements, environmental settlements with the government, losses after contamination incidents, environmental contingent liability, environmental trust funds, and environmental easements. I apply a wide range of regulations contained in rules issued by the Internal Revenue Service, the Environmental Protection Agency (EPA), the Department of Transportation (DOT), the Department of Energy (DOE), the Nuclear Regulatory Commission (NRC), the Health Department, the Labor Department, and other regulatory agencies, both federal and state. I developed guidance concerning research credit claims for performing environmental feasibility studies. I used my knowledge of environmental engineering to assist a fellow engineer on a major chemical company case to analyze environmental remediation activities claimed as research for credit purposes. We were able to reason with the taxpayer and resolve the case with an agreed adjustment. As another example, I performed a valuation of potential future waste streams at a municipal landfill, and determined that the taxpayer was accurate in its assessments. As a result, the issue was closed to mutual satisfaction.

As an indication of my success, I received personal, out-of-the-territory requests for an engineer’s examination at a major private correctional company, where I reached a quick resolution with TP, leading to multi-million adjustments in cost segregation. TP agreed with me against its consultant's opposition. When requested for a large case involving a major shipping company, I identified an emerging issue involving a cross between asset pooling and transfer pricing. I applied the interdisciplinary approach to determine the tax effect of multiple issues. An IRS attorney requested my services in preparing a successful rebuttal in a case involving the claimed loss of a historic property value because of the environmental issues in a real estate case in Massachusetts. When I was requested to work for a major pharmaceutical company by an IRS team beyond my compliance area, I quickly identified the facts and areas of agreement and disagreement. I worked with the TP to find common ground and agreed on adjustments to the claimed bonus depreciation. I was requested for a consultation in a research credit case in California, and I performed a comprehensive risk analysis leading to effective major case planning.

Examples of my customer service include reaching an agreed resolution, and a material adjustment in an R&E case at a major chemical company using Quality Exam Plan (QEP) techniques, which accommodated the taxpayer’s needs. I identified areas of non-compliance involving deductions of capitalizable environmental expenses and non-deductible penalties at a large corporation in Pennsylvania, leading to the TP filing an 1120X to correct the errors, saving the TP and the IRS examination time and resources, and promoting our transparency. I demonstrated flexibility and accommodated the case team members' and coordinators' needs in the fast-paced, large case examination environment. The issue was resolved at the exam level.

I achieve business results by always completing my assignments on time, sometimes prior to the established deadlines. I strive for agreed adjustments, eliminate administrative backlog, and constantly adjust work priorities to current demand. I encourage the achievement of high business results by other team members. I identified a large dollar issue at a major chemical company, engaged an IRS attorney by writing a comprehensive and convincing issue review, and the issue was added to the Team Coordinator’s (TC’s) audit plan.

I share my unique expertise, developed prior to my IRS career, with colleagues working on environmental issues. I promote enthusiasm and collaboration with engineers, and other team members. I volunteered for IPNs multiple times. I volunteered for the team manager’s electronic files initiative and served as a liaison between the team and MITS. I contributed to the team’s issue-knowledge electronic library.

I work continuously on my self-improvement by participating in CPE on a consistent basis, and maintaining NACVA certification. I developed and followed a CLP, proactively approached the team manager for mentoring, and sought temporary assignments for acting. I take ELMS classes on improving personal, management, leadership, and other professional skills. I used my skills and the credibility of my NACVA certification in a domestic production deduction case, where I reasoned with the taxpayer and convinced them to use a calculated value of parts imported from a low-cost country on the US market, instead of the direct cost of imports in the deduction calculations. As a result, the deduction was materially lower.

I investigated and enforced compliance with environmental rules and regulations, including Title V permit applications, and negated settlements to restore environmental damage. I reviewed permit adequacy, and NESHAP and NSPS applicability. Conducted source compliance inspections, and led negotiations to settle cases, or escalated them to adjudication. I assisted in the development of enforcement policy. I consulted the industry and the public in the areas of permitting requirements, non-compliance, and pollution prevention. I assisted corporations with the implementation of environmental management systems (EMS), inspecting and fine-tuning EMS operations. I conducted reviews of financial statements, individual and corporate tax returns, and claims of inability to pay penalties, and financial hardship. I collected fines and penalties. I developed sampling and analysis plans, QA/QC, and contract lab requirements for LUST, Superfund, and state clean-up programs, as well as environmental response procedures. Among the most significant settlements with large corporations, I would mention Allied Signal and Sony Corp. d.b.a. Digital Audio Disk, Ispat Inland Steel, AM General, PSI Energy, Haynes International, Steelcase Corp., Alcoa, REA Magnet Wire, and others. Some enforcement cases involved supplemental environmental projects (SEPs). I performed an evaluation of the design and technology portion of SEPs, and calculated the value and benefit of the projects. I interpreted and applied a wide range of regulations, statutes, and guidelines. I effectively and clearly interpreted and communicated my findings to these companies, and convinced them by reason to take actions beneficial to the environment. I planned different projects, and identified milestones and time frames to accomplish various tasks. I am proficient at planning for changes in priorities or project goals, and modifying my work plan accordingly. I am proficient at adjusting work to ensure that all deadlines are met. I received three promotions and eight merit raises over my tenure with the Indiana government.

Term contract. Concurrent with IDEM, this work was administered through a private firm. I audited environmental concerns at steel mills and coke plants in Ukraine (former USSR). I developed waste management training seminars for central and local Ukrainian governments, and industry representatives, strengthening environmental management in the Ukrainian region of Mariupol. As a part of my international experience on behalf of the U.S. government and private organizations, I established how much money and other resources it would take to bring the aging Ukrainian industry to an acceptable environmental performance level, enabling international assistance, financial aid, and developmental grants. The result was a successful identification of estimated potential liabilities to prospective investors, emanating from the state of environmental protection. I was personally involved in audits at two steel mills and a coke plant located at the Azov Sea shore city of Mariupol. I prepared briefings and investment plans for high-ranking World Bank officials.

Trained personnel at Nizhny Tagil Iron and Steel Works in environmentally sound operational practices.
Coordinated efforts with United States EPA Region V to ensure compliance with environmental standards.
Collaborated with private contractor to administer training programs effectively.
Supported USAID and US EPA initiatives through successful training implementation.

Supervised company projects focused on industrial waste reuse and recycling for large generators.
Engaged directly with Rustavi Steel Mill, Novo-Lipezk Steel Mill, and Chasov-Yar Refractory Materials Factory.
Led negotiations with top-level industry managers and executives to secure project agreements.
Directed investigations and evaluations of waste streams, resulting in effective reduction strategies.
Managed design and installation of on-site pilot projects, including feasibility studies and cost-benefit analyses.
Conducted market studies to assess pricing and impact of new products for customers.
Oversaw daily operations of Engineering Department, reporting directly to VP for Technology.
Resolved conflicts and labor disputes while ensuring efficient team dynamics.

Oversaw lab technicians in testing and analysis of thermal insulation materials.
Crafted quality assurance initiatives and health safety protocols.
Managed installation, tuning, and troubleshooting of recycling/reuse equipment.
Led development projects for on-site and off-site reuse applications to minimize waste.
Facilitated negotiations on project requirements, schedules, and funding allocations.
Persuaded clients to implement phased project portions for enhanced comfort with technology.
Boosted client confidence through demonstration of functional technology prior to project completion.

Formulated, tested, and examined properties of materials for performance evaluation.
Developed standards for replacement materials, including alternatives to asbestos thermal insulators.
Reviewed technical parameters for special application materials to ensure compliance.
Applied various instrumental and analytical methods, providing interpretations of results.
Participated in negotiations of government contracts, enhancing technical specifications utilized in discussions.

• Top Ranked: 10

Graduated cum laude