Stephen advises employers on federal and state employment tax matters, including identifying and analyzing issues, managing ongoing compliance and tax controversies with federal and state authorities, and litigating disputes that cannot be resolved administratively. His practice covers federal employment taxes, including federal income tax withholding, the Federal Insurance Contributions Act (FICA), and the Federal Unemployment Tax Act (FUTA), as well as state taxes, including state unemployment insurance and state income tax withholding.
Audit Defense & Controversy
Stephen represents employers in payroll tax audits, negotiating directly with federal and state authorities to reduce assessments and resolve disputes efficiently. Drawing on extensive federal and state payroll tax audit experience, Stephen identifies areas of payroll tax exposure, such as misclassification, underwithholding, or reporting deficiencies, and develops strategies to resolve them. His audit defense work has helped companies avoid substantial penalties and interest charges, protecting their financial position and their credibility with taxing authorities.
Transactional Tax
Stephen conducts employment tax due diligence for mergers and acquisitions, identifies and quantifies exposure, and guides post-transaction payroll tax integration. Stephen also designs payroll tax reporting structures and leads refund studies that recover overpayments for clients.
Compliance & Advisory
Stephen counsels employers on multistate income tax obligations for business travelers and remote workers. As remote and hybrid work arrangements reshape employer obligations, he helps companies navigate the resulting patchwork of state withholding, unemployment, and registration requirements. Stephen advises employers on the classification of independent contractors under the IRS common-law test and various state classification frameworks. Stephen also advises on the payroll tax implications of equity-based compensation, including stock options, restricted stock units, and other equity awards, as well as qualified retirement plans, nonqualified deferred compensation, and fringe benefit programs, with particular attention to proper withholding and reporting.
Combining fluency in payroll systems with legal analysis, Stephen conducts comprehensive payroll process reviews and internal audits that identify risks and strengthen compliance before problems arise. These proactive reviews routinely uncover misclassifications, reporting errors, and overpayments that, left unaddressed, would result in costly audits or penalties. Clients value his ability to translate complex payroll tax requirements into clear, actionable guidance they can implement with confidence.
Background & Education
Stephen serves as an officer in the U.S. Army Reserve Judge Advocate General’s Corps, advising military commanders on legal matters. Stephen earned his J.D. from Penn State Dickinson School of Law, where he served as a research assistant at the Center for Agricultural and Shale Law and honed his client-facing skills as a clinical student in the Rural Economic Development Clinic.
