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Am Law 100 firm with practices in Business, Digital Assets and Data Management, Intellectual Property, Labor & Employment, Litigation and Tax.

Home | BakerHostetler

What to Expect and How to Prepare: A Guide to Employing Foreign Workers in the Age of Trump

Teresa Goody Guillén Supports New SEC Nominee in Institutional Investor Article

Carolina Alonso Shares Her Journey to the Legal Profession with High School Students

​Bill Bergmann Elected Treasurer of Court of Federal Claims Bar Association; Continues Role on Advisory Council

She has extensive experience advising clients in connection with all facets of federal tax controversies, including IRS audits, IRS appeals and litigation. Michelle serves as co-leader of both the national Transactional Tax and national Tax Controversy and Litigation teams, leader of the Cleveland office's Tax Group and is a member of the Hiring and Recruitment Committee for the Cleveland office.

core/freeform

J.D., Case Western Reserve University School of Law, 2000, 

B.S., Case Western Reserve University, 1994, 

<ul>
<li>Houston Business Journal: Member of team named Deal of the Week (August 9-15, 2024 edition)</li>
<li>Chambers USA: Tax in Ohio
<ul>
<li>Band 1 (2020 to 2024)</li>
</ul>
</li>
<li>The Legal 500 United States
<ul>
<li>Recommended in Tax: Contentious (2019, 2022 to 2024)</li>
<li>Recommended in Tax: Non-Contentious (2021 to 2023)</li>
</ul>
</li>
<li>The Best Lawyers in America®
<ul>
<li>Ohio: Tax Law (2020 to 2025)
<ul>
<li>Best Lawyers® &#8220;Lawyer of the Year&#8221; (2023)</li>
</ul>
</li>
</ul>
</li>
<li>Cleveland YWCA Woman of Professional Excellence Award (2019)</li>
</ul>

Cleveland

BakerHostetler Team Represents CleanArc Data Centers in Partnership with Snowhawk LP

BakerHostetler Advises CBIZ in Acquisition of Marcum LLP

Jeff Paravano, Michelle Hervey, Nick Mowbray Speak to Tax Club of Cleveland

BakerHostetler attorneys, practice areas stand out in The Legal 500 annual guide

Chambers USA Guide 2024 Recognizes 155 BakerHostetler Attorneys and ­66 Practice Areas

BakerHostetler Sponsors Tax Executives Institute Seminar

BakerHostetler Advises Surge Private Equity on Investment into Coastal Amusements

BakerHostetler represents GO Concepts in sale to VC3

BakerHostetler deal team helps facilitate $1.385 billion acquisition

BakerHostetler counsels SurgePE through 2 major deals in 2 weeks

Surge Private Equity adds legal staffing provider to its Avalon platform

BakerHostetler guides client to $700 million financial closing for tech-forward steel recycling mill

BakerHostetler Attorneys and Practice Areas Recognized in The Legal 500 2023 Guide

Chambers USA Guide 2023 Honors 147 BakerHostetler Attorneys and Recognizes 64 Practice Areas

Six BakerHostetler Attorneys Offer Federal Tax Policy and Controversy Program

Patrick Rose, Michelle Hervey and Madison Alexander Advise Sky Peak Through Acquisition

Hundreds of BakerHostetler Attorneys Honored as 2023 Best Lawyers, Ones to Watch and Lawyers of the Year

BakerHostetler Attorneys, Practice Areas Shine in The Legal 500 2022 Guide

Chambers USA Guide 2022 Honors 145 BakerHostetler Attorneys and Recognizes 62 Practice Areas

Michelle Hervey Discusses Section 1202 Considerations

191 BakerHostetler Attorneys Named in 2022 “Best Lawyers” List; 10 Recognized as “Lawyer of the Year”

BakerHostetler Attorneys, Practice Areas Recognized in The Legal 500 Guide for 2021

Chambers and Partners USA Honors 134 BakerHostetler Attorneys and 55 Practice Areas in 2021 USA Guide

President Signed Consolidated Appropriations Act that Includes $900 Billion for COVID-19 Relief

$2 Trillion CARES Act Provides Significant Tax and Workforce Relief for Businesses, Individuals

BakerHostetler Attorneys Make Significant Gains in The Legal 500 Annual Guide

New Markets Tax Credit

Executive Compensation

Tax Controversy and Litigation

Transactional Tax

Tax Credit Finance and Economic Development Incentives

Employee Stock Ownership Plans

<ul>
<li>Advised a U.S. aerospace manufacturing company as a tax counsel in connection with the sale of one of its European-based subsidiaries in a cross-border carve-out sale.</li>
<li>Advised an international technology sales, marketing and support services group as outside counsel on its acquisition of two closely held U.S.-based companies.</li>
<li>Assisted private equity and direct investment clients in designing merger and acquisition structures to obtain and preserve Section 1202 qualified small business stock treatment.</li>
<li>Represented numerous clients with IRS examinations of Bipartisan Budget Act centralized partnership audit regime and Tax Equity and Fiscal Responsibility Act (TEFRA) procedural issues involving historic tax credit, conservation easement and other partnerships. Advised clients regarding open space and historic preservation easement valuation and qualification matters, including substantiation, perpetuity and conservation purpose. Negotiated numerous taxpayer-favorable settlements during examination and at IRS Appeals, utilizing measures such as mediation, the Rapid Appeals Process and requests for technical advice.</li>
<li>Assisted clients in obtaining private letter rulings regarding diverse transactional and planning matters.</li>
<li>Advised clients in distinguishing real estate inventory/dealer property from property held for investment purposes. Negotiated several settlements with IRS Appeals preserving the capital gain treatment on bulk sales of real estate.</li>
<li>Obtained favorable settlements in several Global High Wealth examinations and Tax Court proceedings, including matters relating to private aircraft ownership and usage.</li>
</ul>

Michelle M. Hervey

Michelle M. Hervey

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