Attorney Herman J. Marino has over 45 years of experience in all phases of income, estate, gift and employment tax compliance and litigation including preparation and review of income, estate gift and employment tax returns; negotiation of submission of delinquent returns with IRS special procedures division; federal and state audits and administrative protests; appeals to IRS district and appellate counsel; negotiation of offers in compromise and settlement of IRS levies/liens; income estate and gift tax planning for high net worth individuals, small and mid-sized corporations, limited liability companies, subchapter S corporations, general and limited partnerships; formation of domestic and offshore trusts and other asset-protection devices; and tax planning for nonresident aliens and departing U.S. employees.He also has over 45  years experience in all phases of tax and commercial litigation in U.S. District Courts, U.S. Tax Court, and the U.S. Court of Federal Claims. (Representative list of trials supplied upon request.)