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, Berkeley, Fremont, Hayward, Oakland, San Leandro, Antioch, Concord, Richmond, Novato, San Rafael, Daly City, Redwood City, San Mateo, Milpitas, Mountain View, San Jose, Santa Clara, Sunnyvale, Petaluma, Santa Rosa
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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Recognized by
Criminal Law Specialist, certified by the State Bar of California Board of Legal Specialization (held by only 0.17% of active status California · licensed attorneys)
J.D., Harvard Law School Recognized
B.A., Stanford University Recognized
California licensed attorney since 2004
Former 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

Violent / Serious Strike Felony Charges

Violent / Serious Strike Felony Charges — full-scope representation by senior counsel of the firm.

AUTHORITYStatutory authority furnished on engagement.
§ 01.2

Homicide

Homicide — full-scope representation by senior counsel of the firm.

AUTHORITYStatutory authority furnished on engagement.
§ 01.3

Domestic Violence & Stalking

Domestic Violence & Stalking — full-scope representation by senior counsel of the firm.

AUTHORITYStatutory authority furnished on engagement.
§ 01.4

Sex Crimes

Sex Crimes — full-scope representation by senior counsel of the firm.

AUTHORITYStatutory authority furnished on engagement.
§ 01.5

DUI & Vehicle Offenses

DUI & Vehicle Offenses — full-scope representation by senior counsel of the firm.

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

Criminal Defense Attorney

Will Morehead represents named clients before named tribunals as criminal defense 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.