Joseph Maselli is a Director at PricewaterhouseCoopers where he profides advice to clients and prepares formal written submissions to the IRS on a wide variety of procedural, administrative and technical issues including issue resolution techniques (pre-filing agreements, fast track Appeals and regular Appeals), witness preparation, preparation of protests and presentations to IRS Appeals, post Appeals mediation submissions and presentations and numerous other tax controversy matters. His most recent work involves extensive experience with the research credit, section 199 matters, transferee liability, economic substance, penalty defense, unreasonable compensation, bankruptcy, summons procedures, closing agreements, tax shelters, and unreported income. Joseph’s research credit experience includes the defense of several cases involving internal use software.
Prior to joining PWC in 2006, Joseph held several positions at the Internal Revenue Service including Area Counsel and Regional Counsel, Northeast Region. As Area Counsel he was the legal advisor to the IRS on large business and international industry and he supervised a team of litigators who represented the IRS in the U.S. Tax Court. In both roles he made referrals to the Department of Justice and engaged in alternative dispute resolution.
Education:
J.D., Tax Law/Taxation, Rutgers University School of Law – Camden (1973)
B.A., History, Rutgers University (1970)
Bloomberg BNA Tax Management Portfolios:
556 T.M., Research and Development Expenditures (co-author)