Michael C. Hamersley, Esq., MBA


Hamersley Partners was founded in 2009 by tax lawyer Michael C. Hamersley, a Georgetown University Law graduate, former Big Four accounting firm and tax agency employee, U.S. Congressional candidate, and nationally recognized tax law expert with a proven reputation for professional integrity.   

 

Mr. Hamersley provides consulting services involving a wide array of federal and state tax issues.  These services include business and tax planning, tax due diligence,  client representation before the IRS and FTB, litigation consulting, and expert witness consulting and testimony.  He specializes in tax matters involving corporate and partnership transactions, judicial doctrine analysis, tax shelter issues, and professional responsibility matters.

 

Prior to founding Hamersley Partners, Mr. Hamersley was a member of the Abusive Tax Shelter Task Force of California's Franchise Tax Board from 2004 through 2009, where he was honored with the Golden Superior Accomplishment Award for his negotiation and closure of an abusive tax shelter case that resulted in the largest individual payment of tax, penalties, and interest  in California history.  Before coming to the FTB, he was employed as a mergers and acquisitions tax expert with a Big Four accounting firm.

 

Mr. Hamersley has testified before and/or assisted the U.S. Senate Finance Committee, the U.S.  Senate Homeland Security and Governmental Affairs Committee, the California State Senate Revenue and Taxation Committee, and other legislative bodies.  He has provided expert witness testimony in major tax shelter tort litigation and has instructed students, corporate executives and tax professionals at numerous seminars and conferences.  In the words of one author, "Mike has the rare capacity to explain clearly and in nontechnical terms the transactions about which we have written." (Confidence Games: Lawyers, Accountants, and the Tax Shelter Industry (Rostain & Regan, The MIT Press, 2014, p. x). Mr. Hamersley has has been quoted on tax matters by publications including The Wall Street Journal, The New York Times, The Washington Post, the Los Angeles Times, Forbes Magazine, Fortune Magazine, BusinessWeek,  Tax Analysts Tax Notes Today and Tax Notes magazine, PBS Frontline, and CBC News.  Additional background information is provided below.

 

Appeal of Khoury, Board of Equalization Decision/Hearing (B5) / Hearing Summary

 Expert Witness Testimony, Yung et al. v. Grant Thornton LLP  [Forbes]

FTB Chief Counsel Ruling 2009-1

FTB Chief Counsel Ruling 2008-1

FTB Chief Counsel Ruling 2007-3



* Mr. Hamersley offers tax consulting and tax advisory services.  He is an attorney but is not authorized and does not engage in the practice of law within the State of California.   Mr. Hamersley's tax advice, as well as all communications made to Mr. Hamersley in connection with such tax advice, are privileged communications protected from disclosure, under the same common law protections afforded communications between an attorney and client seeking legal advice, pursuant to Internal Revenue Code Section 7525 and California Revenue and Taxation Code Section 21028.

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