With more than two decades of experience, Hale defends clients in tax audits, appeals, and Tax Court litigation, with a focus on tax disputes, international tax, employee retention credits, qualified opportunity zones, conservation easements, and captive insurance.
Hale has a proven track record of success in the courtroom, with extensive experience litigating cases before the Tax Court, District Courts, and Federal Courts of Appeal. His deep understanding of tax law enables him to secure favorable rulings from the IRS National Office for his clients. When a private letter ruling is not required, Hale skillfully navigates other administrative remedies to achieve optimal tax outcomes.
As a prolific tax writer, Hale has authored over 300 major articles in leading law reviews and tax journals. His work is frequently cited by peers in prestigious journals, legal briefs, and books, underscoring his authority in the field.
In addition to his writing, Hale is a sought-after speaker, regularly lecturing at regional and national organizations on a wide array of tax topics.
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- Opportunity Zones: Tax Benefits, Evolving Guidance, OBBBA Changes, and More, March 25, 2026, Palm Beach Tax Institute March Meeting
- Charitable Giving – Analyzing Four Recent IRS Enforcement Efforts, February 18, 2026, Chattanooga Tax Practitioners Monthly Meeting
- Limited Partner Exception to SECA Taxes, February 18, 2026, Chattanooga Tax Practitioners Monthly Meeting
- Malta Pension Plans: International Disputes Generating Novel Tax and Procedural Issues, January 22, 2026, FICPA 44th Annual International Tax Conference
- ERC Audits, Promoter Investigations, and IRS Enforcement: What Practitioners Need to Know, December 8, 2025, Minnesota CLE 2025 Tax Institute
- Employee Retention Credits: Separating Fact from Fiction as Tax Disputes Evolve, December 4, 2025, 63rd Annual Great Plains Federal Tax Institute
- Self-Employment Taxes, Limited Partner Exception, Recent Cases and Future Regulations, December 4, 2025, 63rd Annual Great Plains Federal Tax Institute
- Exploring Four IRS Enforcement Campaigns on Charitable Donations, December 4, 2025, ATA 2025 Tax Conference
- Identifying and Explaining Various IRS Voluntary Disclosure Program, November 19, 2025, Tennessee Society of CPAs Federal Tax Conference
- Self-Employment Taxes, Limited Partner Exception, Recent Cases and Future Regulations, November 19, 2025, Tennessee Society of CPAs Federal Tax Conference
- Litigation Developments and Notable Decisions, November 13, 2025, TEI St. Louis Federal Tax Program
- Charitable Giving – Analyzing Four Recent IRS Enforcement Efforts, November 6, 2025, University of Akron 2025 National Tax Conference
- Compliance Issues related to ERISA Covered Plans and IRAs, October 27, 2025, NYSSEA 38th Annual Conference
- SECA Taxes: Limited Partner Exception, Recent Cases, and Future Regulations, October 27, 2025, NYSSEA 38th Annual Conference
- Foreign Gifts, Trusts, Retirement Plans: Governmental Actions and Pending Issues, October 26, 2025, NYSSEA 38th Annual Conference
- SECA Taxes, Limited Partner Exception, Five-Decade Evolution, and Recent Cases, September 26, 2025, WSCPA webinar
- Notable Federal Tax Dispute Issues in 2025, August 19, 2025, GSCPA Southeast Accounting Show
- Foreign Trust, Partnership and Corporation Filing Requirements, July 22, 2025, GSCPA Annual Estate Planning Conference
- Opportunity Zones: Tax Benefits, Evolving Guidance, Criticisms, Elections, and Early IRS Attacks, June 17, 2025, GSCPA Real Estate Conference
- SECA TAX Issues and Limited Partners, June 5, 2025, 76th Annual Virginia Conference on Federal Taxation 2025
- Comprehensive IRS Voluntary Disclosure Program and Others: Key Aspects and Developments, May 27, 2025, Estate Planning Council of North Georgia 101-Level Presentation
- Litigation Hot Topics, May 1, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- The Large Partnership Compliance Program Meets the BBA, April 22, 2025, API 90th Annual Federal Tax Forum
- Employee Retention Credits: Separating Fact from Fiction as Tax Disputes Evolve, March 21, 2025, William & Mary Law School 70th Annual Virtual Tax Conference
- Recognized by The Legal 500 United States in the area of US taxes: contentious (2025)
- American College of Tax Counsel, Fellow (2019-2021)
- Chambers USA - Tax Litigation Leader (2009-2021)
- Georgia Super Lawyers - Tax (2012-2022)
- Best Lawyers - Litigation and Controversy-Tax (2019-2022, 2026) and Tax Law (2026)
- Legal 500 – Tax Litigation and Controversy (2015-2021)
- Journal of International Taxation, Board of Advisors
- Journal of Taxation, former Editorial Board member and tax columnist
- IRS-Practitioner Liaison Committee, Georgia Bar representative
- Journal of Tax Practice & Procedure, Editorial Board member
- Georgia Bar Tax Section, former President
- Georgia Bar Journal, former Editorial Board member
- GSU Low-Income Taxpayer Clinic, Advisory Committee member
- Georgia Council for International Visitors, Citizen Diplomat
- American Bar Association, Tax Section, Member
- Atlanta Bar Association, Tax Section, Board of Directors
- American Citizens Abroad, Former Tax Advisory Council member
- Latin American Association, Member
- World Trade Center Atlanta, Member
- Southern Capital Forum, Member
- Law360 Tax Authority International, Editorial Board
- Georgia
- Texas
- Florida
- District of Columbia
- U.S. Tax Court
- LL.M. in Taxation, University of Florida Levin College of Law, Graduate Tax Scholar
- LL.M. - Magister (International Law), with highest distinction, Universidad de Chile
- J.D., University of Kansas School of Law
- M.A., with honors, University of Kansas
- B.S., with distinction, University of Kansas