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Mr. Merritt was born in Hickory, North Carolina, in 1938. He received his A.B. degree from Duke University in 1959 and his LL.B. from Harvard Law School in 1962. Mr. Merritt became a partner in the firm in 1972 and was the senior tax partner in the firm’s Washington, D.C., office from 1981 to 1988. He served as Trial Attorney, Regional Counsel, Internal Revenue Service, San Francisco, California, from 1964 to 1968. During 1983, Mr. Merritt served as a consultant in the Office of Chief Counsel, Internal Revenue Service. Mr. Merritt became Of Counsel to the firm in 1998, and in 2002, after 14 years in the firm’s San Francisco office, he returned to Washington, D.C.

Mr. Merritt engages in all aspects of tax litigation. Mr. Merritt’s federal tax litigation practice includes civil and criminal litigation, audits and investigations. He has appeared at all administrative levels of the Internal Revenue Service, Treasury Department and other agencies. He has worked extensively on complex investigations that require coordination between various federal and state agencies. Mr. Merritt has tried a substantial number of federal tax cases in various forums as well as numerous state and local tax cases. He is admitted to practice before the United States Tax Court and the United States Claims Court as well as various United States District Courts, state trial courts and appropriate appellate courts including the United States Supreme Court. He has also represented attorneys and accountants in investigations and litigation involving their advice and assistance to their clients.

Mr. Merritt’s background in tax litigation and administrative practice gives him an invaluable insight into the effective resolution of tax disputes. Mr. Merritt uses his expertise to seek prompt administrative settlement of federal tax cases when possible. He is, however, prepared to litigate any dispute in the most appropriate forum. His dispute resolution experience includes complex fact issues involving valuation, inventory and tax accounting methods, transfer pricing (Section 482), investment tax credit, etc. as well as sophisticated legal issues.

Mr. Merritt is the Chair of the American College of Tax Counsel. He has been active in the American Bar Association, the State Bar of California, and the Bar Association of San Francisco. Mr. Merritt was a member of the Council, Section of Taxation, American Bar Association (1990-1993). He chaired a Task Force on Director of Practice and Civil Penalties of the Administrative Practice Committee, a Subcommittee on the Civil Penalties Task Force and the Small Business Subcommittee on the Compliance Task Force, Tax Section, American Bar Association. He was chair of the Section of Taxation, Bar Association of San Francisco. Mr. Merritt has been selected to be included in the Best Lawyers in America Directory in the area of Tax Law for more than ten years.

Mr. Merritt was chair of the American Bar Association’s Section of Taxation Committee on Administrative Practice from 1980 to 1982, of the Committee on Employment Taxes from 1988 to 1990, and of the Committee on Special Projects from 1996 to 1998. He is a Master in the J. Edgar Murdock Inn of Court (Tax). He lectured on Federal Tax Procedures at Golden Gate University from 1970 to 1974. He has lectured and written extensively for a variety of continuing legal education and professional organizations, including the American Law Institute, American Bar Association, Tax Executives Institute, New York University and others. His published articles include: “Understanding and Mitigating the Consequences of Reclassification of Workers from Independent Contractors to Employees,” 43rd. U.S.C. Tax Institute on Federal Taxation, Chapter 12 (1991); “Transfer Pricing-New IRS Enforcement Weapons,” Kokusai Shoji Homu (October 1990)(published by The Japanese Institute of International Business Law); “DRA Changes Affecting Charitable Contributions, Estate and Gift Tax Valuations and Appraisers,” 16 Tax Adviser 140 (March 1985) (coauthored with Tony M. Edwards); “New Procedures Used by the IRS to Attack Tax Shelters,” 10 Tax Section News, State Bar of California 6 (Summer 1984); “TEFRA Tightens Compliance,” 69 A.B.A. Journal 456, 626 (April and May, 1983); “The Use of the Freedom of Information Act in Federal Tax Matters,” 39 N.Y.U. Institute on Federal Taxation 38 (1981).