Jeffrey Allen Miller
Mr. Miller is of counsel in the Vorys Columbus office and a member of the tax group. He has regularly advised business and individual clients in federal income and employment tax matters regarding: (1) the permissibility of federal income and employment tax return positions; (2) tax compliance and procedures; (3) the federal income and employment tax consequences of proposed transactions; and (4) alternative structures to minimize federal income and employment tax liability. Mr. Miller regularly advises clients on the consequences of employment tax reporting and withholding errors, and correction and penalty abatement request procedures for same. He regularly advises and assists clients’ in-house or external accountants during tax audits in responding to proposed audit adjustments by audit agents or preparing written appeals. Mr. Miller has represented clients before the Internal Revenue Service in cases of disputed liability for federal income tax and federal employment tax. Mr. Miller also has represented taxpayers in federal excise tax matters before both the Internal Revenue Service and the Alcohol and Tobacco Tax and Trade Bureau. He regularly advises clients in tax collection matters and has represented taxpayers before the Internal Revenue Service in collection matters.
Mr. Miller is a six-year veteran of the United States Naval Nuclear Power Program and has expertise in mechanics and integrated operation of power plant systems. He has utilized this expertise to work with major public utilities to obtain and defend function-based tax exemptions for various equipment. Additionally, Mr. Miller has advised clients regarding federal tax credits available for power production activities.
His notable experience includes:
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Analyzing federal income tax issues for transactions in excess of $1 billion involving complex business structures
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Achieving abatement by the Internal Revenue Service of over $60 million in civil tax penalties in 2008 and 2009
Mr. Miller received his J.D. from The Ohio State University Michael E. Moritz College of Law and his B.S. in business administration/accounting summa cum laude from The Ohio State University.