Overview
Prior to joining Amundsen Davis, Daniel led the IRS Office of Chief Counsel, in partnership with the U.S. Department of Justice, in Norcave Properties, L.L.C. v. Internal Revenue Service, a landmark federal tax case involving a taxpayer's attempt to obtain a pre-payment jury trial to challenge IRS accuracy-related penalties following the Supreme Court’s decision in SEC v. Jarkesy. The Western District of Louisiana dismissed the case for lack of jurisdiction in August 2025, and the Fifth Circuit affirmed in August 2026, holding that the accuracy-related penalties are treated as tax under the Internal Revenue Code and that federal law barred federal district court jurisdiction over the taxpayer’s pre-payment district court challenge. The Fifth Circuit’s decision established an important precedent, which helped define the boundaries of tax litigation in the post-Jarkesy era.
