Milan K. Patel

Managing Partner  |  Anaford
JURISDICTIONS QUALIFIED IN

United States (NY, NJ)

TOP 3 AREAS OF EXPERTISE

Succession planning
Dispute resolution
Asset holding structures

Q&A

What has been the highlight of your practice over the past five years?

Filing a lawsuit against the U.S. Internal Revenue Service (IRS) for violation of the Administrative Procedure Act (APA). For decades, the IRS has enjoyed what has been coined "tax exceptionalism," essentially meaning that agency actions on tax matters have avoided the same scrutiny to which other federal agencies have been subject under the APA. This lawsuit has the potential to change the practice of tax before the IRS and hold the IRS more accountable to it stakeholders, i.e., taxpayers.