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Feingold & Alpert L.L.P.
- 1330 Avenue of the Americas
- New York, New York
- 10019
- Phone: (212) 582-8000
- Website
Description
By way of background, an individual who is not a domiciliary of NYC is nevertheless considered a resident of NYC for income tax purposes for a year if that individual (a) has a permanent place of abode available in NYC and (b) spends more than 183 days in NYC during such year (other than while in transit between two points outside NYC).
Mr. Alpert is of counsel to the firm. He graduated from Columbia Law School in 1956 where he was an editor of the Law Review. Prior to Mr. Alpert becoming a member of the firm, and apart from the period during which he served in the office of Tax Legislative Counsel, U.S. Treasury Department, Mr. Alpert was associated with and a senior partner of Roberts & Holland for over 39 years. Mr.
Rejecting each of the arguments advanced by the Department and dismissing the asserted deficiency, the DTA held that the totality of the evidence taken as a whole, including the client’s electronic calendar, the other documentary evidence submitted at the hearing and the extensive corroborating testimony of the client and the nine other witnesses who testified on the client’s behalf, made it abundantly clear that the client had met his burden and established that he was not present in NYC on any of the days in issue.
The skills and experience of the firm's attorneys complement one another and permit the firm to offer a full range of legal services. In addition, we work extensively with non-U.S. counsel in various parts of the world and, accordingly, have the ability to draw on their expertise in connection with our clients' non U.S. matters.
Mr. Feingold, the firm's senior partner, graduated cum laude from Brooklyn Law School in 1969, where he was an editor of the Law Review. Prior to the formation of Feingold & Alpert, Mr. Feingold spent over 23 years with Roberts & Holland, a New York based law firm, concentrating his practice in international tax and fiscal matters and at which he served as a partner and a member of the Executive Committee and Chairman of the International Specialist Group. Mr.