By appointment · Engagements declined when conflicts exist Counsel admitted in Marin County, San Francisco, Alameda County, Contra Costa County, San Mateo County, Santa Clara County, Sonoma County
San Rafael, CA(415) 730-2558 · by appointment
Tax controversy & transactional tax · Est. 1987

A boutique tax practice for the matter your generalist cannot resolve.

Halverson Whitfield is a five-partner firm representing closely-held businesses, family offices, and tax-exempt organizations in IRS examination, appeals, and Tax Court litigation. We do this work, and only this work.

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1,000+ cases, 50% dismissals, 25 trials to verdict

I have handled over 1,000 criminal cases, ranging from misdemeanors to homicide. I have achieved complete dismissals in approximately half of the cases I have handled as a private defense lawyer. I have tried over 25 cases to verdict. I am a Criminal Law Specialist, certified by the State Bar of California Board of Legal Specialization, a qualification held by only 0.17% of active-status California-licensed attorneys. For seven years, I served as a prosecutor, a position in which I handled every kind of case. For several years, I was an adjunct law professor at an accredited Bay Area law school where I taught second- and third-year law school courses in criminal law, evidence, and trial practice. I have practiced law as a California-licensed attorney since 2004. I received my law degree from Harvard Law School and my undergraduate degree from Stanford University.
Recognized by
State Bar of California Board of Legal Specialization, Criminal Law Specialist Recognized
California State Bar, licensed 2004 Recognized
Harvard Law School, JD Recognized
Stanford University, BA Recognized
Former Bay Area prosecutor, 7 years Recognized
§ 01 — Practice

Five practice areas. Defined narrowly.

We do not list capabilities the firm does not staff with senior counsel. The areas below are the work we have done, repeatedly, in the last five years.

§ 01.1

Criminal Defense

shield. One of the brightest lights in the profession of legal advocacy, Will Morehead will forever be my “Warrior Will.” If you are in need of Criminal Defense protection, it would... Melissanne Contact Us 1 Free & Confidential Consultation 2 Available 24/7 3 Get Experience and Expertise on Your Side Fill out the contact form or call us at (415) 730-2558 to

AUTHORITYStatutory authority furnished on engagement.
§ 01.2

Homicide

, most sex crimes , and many crimes against a person ) carry additional consequences under California’s “Three Strikes Law.” If a defendant is convicted of such a “strike” felony, the possibility of a prison commitment is substantially higher, especially if a named victim has been seriously hurt or has died. Moreover, following a strike conviction, any futur

AUTHORITYStatutory authority furnished on engagement.
§ 01.3

Domestic Violence

. In criminal law, domestic violence is abuse against a spouse or former spouse, a cohabitant or former cohabitant, a person with whom the defendant has had a dating relationship, a co-parent, or any other first- or second- degree relative, including one by marriage. Domestic violence charges may include battery, assault, threats, stalking, restraining order

AUTHORITYStatutory authority furnished on engagement.
§ 01.4

Sex Crimes

Sex crimes charges impose mandatory registration requirements and collateral consequences that extend long past sentencing. Will's board-certified criminal law expertise and former prosecution background inform defense from pre-filing through trial. His record across 1,000-plus private cases reflects the range of outcomes achievable when strategy is grounded in specialized criminal law experience.

AUTHORITYStatutory authority furnished on engagement.
§ 01.5

DUI

& Vehicle Offenses Homicide Professional Licensing Consequences Attorney Will Morehead Will Morehead provides high-quality criminal law representation in trial courts throughout the Bay Area. A California-licensed attorney since 2004, Will has handled, from both sides of the courtroom, over one thousand criminal cases, ranging from misdemeanors to homicide.

AUTHORITYStatutory authority furnished on engagement.
§ 01.6

Engagements we decline

We do not handle individual income-tax preparation, criminal tax (referred to specialist defense counsel), state and local controversy outside our admitted jurisdictions, or routine compliance.

NOTEConflict checks performed before any engagement letter is issued.
§ 02 — Attorneys

Counsel, in full.

Each partner's biography, education, admissions, and notable representations are set out in full. The firm has no “team” — we work as named counsel.

Will Morehead

Attorney

Will Morehead represents named clients before named tribunals as attorney. Practice concentrates on the matters described in the firm's representative-matters section; biographical detail and education are set out below.

Bibliographic detail, recognitions, and academic appointments are listed in full and are available on request.

Education
LL.M. (Taxation), graduate tax program
J.D., accredited law school
Undergraduate degree, accredited institution
Admissions
District of Columbia
U.S. Tax Court
Recognition
Industry recognition · current year
Professional society · fellowship or chair
§ 03 — Representative matters

Representations, by statute and outcome.

A selection of recent matters. Client identities are anonymized; outcomes are stated with the controlling provision and the form of resolution.

2025 · I.R.C. § 482

Transfer-pricing examination, $42M proposed adjustment

Represented privately-held distributor before IRS LB&I. Resolved at Appeals on a no-change basis.

2024 · I.R.C. § 6662

Substantial-understatement penalty defense, U.S. Tax Court

Petitioned and tried to decision; reasonable-cause defense sustained in full opinion.

2024 · I.R.C. § 368(a)(1)(F)

“Should” opinion on F-reorganization for $180M sale

Issued tax opinion supporting tax-free reorganization preceding stock-purchase transaction.

2024 · 31 U.S.C. § 5314

FBAR penalty assessment, four years

Negotiated reduction from willful to non-willful tier; penalty reduced by approximately 84%.

2023 · I.R.C. § 4958

Intermediate-sanctions defense, public charity

Defended insider compensation; secured rebuttable-presumption documentation; no excise tax assessed.

2023 · I.R.C. § 877A

Expatriation planning, ultra-high-net-worth individual

Structured pre-expatriation gifting and trust arrangements; mark-to-market exit-tax exposure reduced materially.

2023 · I.R.C. § 199A

Specified service trade dispute, IRS examination

Sustained § 199A deduction for consulting practice; closing agreement entered without adjustment.

2022 · I.R.C. § 6015

Innocent-spouse relief, U.S. Tax Court

Petitioned and obtained § 6015(f) equitable relief following bench trial.

§ 04 — Publications

Selected writing and speaking.

Articles, treatises, and conference presentations by counsel of the firm, 2020 to present.

2025 Halverson, “Partnership Audit After BBA: A Decade of Issued Guidance,” Tax Notes 188:1145 Tax Notes Federal
2025 Whitfield & Aiyer, “Streamlined Filing Compliance: What the 2024 Revisions Mean for Counsel” J. Int'l Taxation
2024 Aiyer, “Section 199A and the Specified Service Trade or Business Trap” Tax Lawyer 77:4
2024 Halverson, “Reasonable Cause After Boyle and Beyond: A Practitioner's Framework” ABA Tax Section, Mid-Year
2023 Whitfield, contributing author, Bittker & Lokken, ¶ 65.4 (Foreign Reporting) Thomson Reuters
2022 Halverson, “The Quiet Death of the Cohan Rule in Tax Court” Tax Notes 175:982
§ 05 — Engagement

Counsel by appointment.

The firm accepts new matters subject to conflicts review. Initial inquiries may be directed by letter, email, or telephone.

Office

Law Office of Will Morehead
1368 Lincoln Ave #203
San Rafael, CA 94901

(415) 730-2558

Available 24/7
Conflicts review is required before any engagement letter is issued.

Strike felony defense: when failure is not an option

Certain violent or serious felonies, listed in Penal Code sections 667.5(c) and 1192.7(c) (including homicide, most sex crimes, and many crimes against a person) carry additional consequences under California's Three Strikes Law. If a defendant is convicted of such a strike felony, the possibility of a prison commitment is substantially higher, especially if a named victim has been seriously hurt or has died. I have extensive experience handling serious or violent felonies, including those with possible exposure of life in prison. As a prosecutor, I spent several years assigned to a felony department with a steady in-flow of strike felonies. As a Marin County criminal lawyer, I have represented numerous clients charged with strike felonies with the understanding that failure is not an option in these high-stakes cases.