Someone
threw over my internet transom an email from the AAG announcing the retirement
of Dennis Donohue. Given the subject
matter, I did not think anyone would object to my copying and pasting the
contents here:
Dennis Donohue is retiring
from his role as Chief Senior Litigation Counsel today.
After graduating with a
Masters of Tax Law from George Washington University’s National Law Center,
Dennis began his career with the Tax Division in 1971. His original intention
was to complete his four-year commitment and then leave for private practice.
But he quickly developed a passion for representing the United States in
complex tax litigation. Beginning with the first wave of abusive shelters in
the 1980s, through the corporate abusive shelters of the 1990s, and continuing
to the present day, Dennis successfully litigated numerous cases against some
of the most formidable tax litigators in the country. Abusive tax shelter
schemes such as Corporate Owned Life Insurance (COLI) and Structured Trust
Advantaged Repackaged Securities (STARS) were rejected by the courts as a
result of Dennis’s dogged advocacy. Dennis’s efforts over the years brought
billions of dollars into the Treasury and contributed to the tax law’s
development.
As Chief Senior Litigation
Counsel, Dennis was called on to develop and supervise teams of trial attorneys
and administrative professionals from across the Division. He worked
extensively with the Internal Revenue Service, IRS Chief Counsel's Office and,
at times, with other Government agencies. Over his career, Dennis worked with
top economists, academics, and other expert witnesses from around the world,
resulting in courtroom presentations that distilled complex transactions into
understandable concepts. While each team differed based on the nature of the
case, they had one thing in common— forming to immediately face top tax practitioners
in our nation’s most challenging and sophisticated tax cases.
Dennis has been on the
forefront of developing new strategies to present complicated, technical cases
to judges and juries throughout his career. His innovative techniques and trial
tactics have been adopted by other attorneys to enhance their overall
presentation of evidence in court. In the mid-1990s, a new breed of dauntingly
intricate shelters surfaced, designed by sophisticated tax professionals for
corporations and high-net-worth individuals. These cases often generated
millions of pages of documents and thousands of exhibits. Dennis responded by
becoming one of the pioneers in presenting evidence electronically and leading
the Division to the new frontier of electronic court presentation.