Nicholas Ernick

Background

About Nicholas Ernick

As an experienced Estate Tax Attorney, I conduct independent examinations of large, complex Federal estate and gift tax returns spanning all regions of the United States. These returns often include unusually difficult or elaborate legal, financial, or investigative issues, novel issues which are likely to set precedents in the field of Federal transfer tax law, or intricate challenges in the valuation of extremely large real estate holdings, startup companies and other closely held businesses, artwork, and intangibles such as intellectual property. In addition, I provide support to the IRS Office of Chief Counsel and U.S. Department of Justice in litigating estate and gift tax cases in Federal trial and appellate courts. These primarily involve court cases resulting from my examinations, as well as select other docketed cases referred to me for subject-matter consultation and trial assistance. See the Projects section below for summaries of court cases on which I have collaborated. I was recognized with an Assistant Attorney General's Award for Special Contribution from the Department of Justice Tax Division at the 40th Annual Awards Ceremony on November 1, 2017, for my contributions to two litigated court cases decided in the government's favor. The skills required to successfully resolve my case assignments include expertise in Federal tax laws; a comprehensive understanding of state property, trust and probate laws; strong investigative ability to identify undisclosed assets of the estate and unreported gifts made by the decedent during life; analysis and interpretation of a wide variety of legal documents, financial statements, and asset appraisals; ability to decipher and challenge attempts to exclude property interests from transfer taxation through well-planned and complex legal devices; strong legal research and writing skills; ability to negotiate with highly competent taxpayer representatives on complex points of law and fact affecting proposed adjustments to the tax liability; and a high degree of originality in developing novel legal or valuation rationales on issues where there are no suitable precedents.