J. Paul Varner

J. Paul

Varner

Overview

Paul has extensive experience in tax controversy matters. He is a fellow of the American College of Tax Counsel.

Experience

Controversies

  • Fed Gift Tax Controversy.  Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.
  • Fed Gift Tax Controversy.  Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.   
  • Fed Estate Tax Controversy.  Representation of estate in the U.S. Tax Court to contest the disallowance of a charitable deduction for a post mortem grant of a conservation easement.
  • Fed Income Tax Controversy.  Representation of taxpayers before the IRS Appeals Division and the U. S. Tax Court to contest proposed assessments of income tax.
  • State Tax Controversy.  Representation of multi-state corporation in Miss. Chancery Court involving the issue of how to apportion income earned from electronic commerce.
  • State Tax Controversy.  Representation of out-of-state individual taxpayer in multi-million dollar Miss. income tax assessment;  taxpayer could not post jurisdictional bond, so relief was secured in TRO action in Miss. Chancery Court resulting in favorable settlement for taxpayer of approximately 25% of original assessment.
  • State Tax Controversy.  Representation of Fortune 500 company in multi-million dollar income tax assessment and refund action in Miss. Chancery Court resulting in $4,000,000 refund (issue was whether gain on sale of business was business income or nonbusiness income under UDITPA).
  • State Tax Controversy. Representation of Fortune 500 company in Million Dollar plus assessment of income tax from the disallowance of royalties paid to an affiliate for use of affiliate's intellectual property.
  • State Tax ControversyRepresentation of multi-state corporation seeking refund of state use taxes pursuant to exemption based on payment of sales tax to another state on the same transaction.  Weeks Dredging & Contracting, Inc. v. MS State Tax Commission,  521 So. 2d 884 (Miss. 1988).
  • State Tax Controversy.   Representation of multi-state corporation in Miss. Chancery Court contesting the disallowance of deductions for premiums paid to captive insurance company.

Planning

  • Tax Deferred Exchanges.  Representation of numerous taxpayers in structuring and documenting forward and reverse like kind exchanges of real property.
  • Corporate Reorganizations.  Representation of numerous corporations in structuring acquisitive and divisive tax-free reorganizations.
  • Private letter Rulings.  Representation of numerous taxpayers to successfully obtain private letter rulings on various issues from both the IRS and the Miss. State Tax commission.

Distinctions

  • American College of Tax Counsel, Fellow
  • Chambers USA, America's Leading Lawyers for Business
    • Tax (Mississippi), 2022
  • Best Lawyers in America®
    • Tax Law, 2007-2023
    • Trusts and Estates, 2001-2023
    • Lawyer of the Year, Trusts and Estates, 2017
    • Lawyer of the Year, Tax Law, 2015, 2018
  • Chambers HNW
    • Private Wealth Law (Mississippi), 2017-2022
  • Super Lawyers®
    • Mid-South Super Lawyers, Tax: Business, 2006-2008, 2011-2018
    • Top 50: Mississippi Super Lawyers, 2016
  • Certified Public Accountant, Mississippi
  • Mississippi Tax Institute, Board of Trustees, 1993-1995
  • Martindale-Hubbell®
    • AV®– Preeminent™ Peer Review Rated

Bar Admissions

  • Mississippi, 1982

Education

  • New York University, LL.M., Taxation, 1984
  • University of Mississippi, J.D., 1982
    • Editorial Board, Mississippi Law Journal
  • University of Mississippi, B.B.A., Accounting, 1977

Associations

  • American Bar Association
    • Taxation Section
      • State and Local Tax Committee
  • Institute for Professionals in Taxation
  • Capital Area Bar Association
  • National Association of Property Tax Attorneys
  • Mississippi Bar Association
    • Taxation Section
  • Mississippi Society of Certified Public Accountants
    • Board of Governors, 1987-1989
    • Board of Governors, 1997-1999

Papers, Presentations & Publications

Civic Involvement

  • Andrew Jackson Council of the Boy Scouts of America, Executive Board, Board Member
  • YMCA of Metro Jackson, Board of Directors, Former Chairman
  • Community Foundation of Greater Jackson, Former Vice Chair
  • Mississippi Hurricane Recovery Fund, Former Officer

J. Paul

Varner

Overview

Paul has extensive experience in tax controversy matters. He is a fellow of the American College of Tax Counsel.

Experience

Controversies

  • Fed Gift Tax Controversy.  Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.
  • Fed Gift Tax Controversy.  Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.   
  • Fed Estate Tax Controversy.  Representation of estate in the U.S. Tax Court to contest the disallowance of a charitable deduction for a post mortem grant of a conservation easement.
  • Fed Income Tax Controversy.  Representation of taxpayers before the IRS Appeals Division and the U. S. Tax Court to contest proposed assessments of income tax.
  • State Tax Controversy.  Representation of multi-state corporation in Miss. Chancery Court involving the issue of how to apportion income earned from electronic commerce.
  • State Tax Controversy.  Representation of out-of-state individual taxpayer in multi-million dollar Miss. income tax assessment;  taxpayer could not post jurisdictional bond, so relief was secured in TRO action in Miss. Chancery Court resulting in favorable settlement for taxpayer of approximately 25% of original assessment.
  • State Tax Controversy.  Representation of Fortune 500 company in multi-million dollar income tax assessment and refund action in Miss. Chancery Court resulting in $4,000,000 refund (issue was whether gain on sale of business was business income or nonbusiness income under UDITPA).
  • State Tax Controversy. Representation of Fortune 500 company in Million Dollar plus assessment of income tax from the disallowance of royalties paid to an affiliate for use of affiliate's intellectual property.
  • State Tax ControversyRepresentation of multi-state corporation seeking refund of state use taxes pursuant to exemption based on payment of sales tax to another state on the same transaction.  Weeks Dredging & Contracting, Inc. v. MS State Tax Commission,  521 So. 2d 884 (Miss. 1988).
  • State Tax Controversy.   Representation of multi-state corporation in Miss. Chancery Court contesting the disallowance of deductions for premiums paid to captive insurance company.

Planning

  • Tax Deferred Exchanges.  Representation of numerous taxpayers in structuring and documenting forward and reverse like kind exchanges of real property.
  • Corporate Reorganizations.  Representation of numerous corporations in structuring acquisitive and divisive tax-free reorganizations.
  • Private letter Rulings.  Representation of numerous taxpayers to successfully obtain private letter rulings on various issues from both the IRS and the Miss. State Tax commission.

Distinctions

  • American College of Tax Counsel, Fellow
  • Chambers USA, America's Leading Lawyers for Business
    • Tax (Mississippi), 2022
  • Best Lawyers in America®
    • Tax Law, 2007-2023
    • Trusts and Estates, 2001-2023
    • Lawyer of the Year, Trusts and Estates, 2017
    • Lawyer of the Year, Tax Law, 2015, 2018
  • Chambers HNW
    • Private Wealth Law (Mississippi), 2017-2022
  • Super Lawyers®
    • Mid-South Super Lawyers, Tax: Business, 2006-2008, 2011-2018
    • Top 50: Mississippi Super Lawyers, 2016
  • Certified Public Accountant, Mississippi
  • Mississippi Tax Institute, Board of Trustees, 1993-1995
  • Martindale-Hubbell®
    • AV®– Preeminent™ Peer Review Rated

Bar Admissions

  • Mississippi, 1982

Education

  • New York University, LL.M., Taxation, 1984
  • University of Mississippi, J.D., 1982
    • Editorial Board, Mississippi Law Journal
  • University of Mississippi, B.B.A., Accounting, 1977

Associations

  • American Bar Association
    • Taxation Section
      • State and Local Tax Committee
  • Institute for Professionals in Taxation
  • Capital Area Bar Association
  • National Association of Property Tax Attorneys
  • Mississippi Bar Association
    • Taxation Section
  • Mississippi Society of Certified Public Accountants
    • Board of Governors, 1987-1989
    • Board of Governors, 1997-1999

Papers, Presentations & Publications

Civic Involvement

  • Andrew Jackson Council of the Boy Scouts of America, Executive Board, Board Member
  • YMCA of Metro Jackson, Board of Directors, Former Chairman
  • Community Foundation of Greater Jackson, Former Vice Chair
  • Mississippi Hurricane Recovery Fund, Former Officer