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Jeff Mitchel
Ross B. Newman
Sylvia Burroughs

Jeff Mitchel

Professional Experience:

1998 - Present - Mitchel Zuniga & Smith, CEO

Serves as the chief executive officer of Mitchel Zuniga & Smith and oversees the firm's tax, CFO services and business consulting practices. Responsible for the firm's strategic planning, recruiting, and marketing and strategic alliance programs. Responsible for logistical and infrastructure support and marketing in the U.S. Directs the firm's tax compliance and tax controversy practice, and works with clients on a broad range of tax issues. Consults on tax planning to assist clients in minimizing foreign, domestic, and state and local taxes. Extensive experience serving closely-held businesses in many industries and professions including construction, real estate, manufacturing, medical services, printing, consulting and law.

1978 - 1998 - Internal Revenue Service: Examination Division, Revenue Agent

Performed audits of a broad range of taxpayers, including many large corporate taxpayers in the Coordinated Examination Program (CEP). Worked on cases involving extensive fraud and substantial unreported income. Performed audits of banks, savings and loans and other large financial institutions, as well as businesses in other industries before exiting government service as a GS-13 revenue agent. Headed two fraud task forces charged with investigating a massive real estate fraud and criminal activity at a public company. Investigated funds laundered through numerous shell entities located here in the U.S. and in offshore tax haven countries.

Education:

UCLA B.A.
Graduate studies in accounting and tax at California State University at Long Beach.

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Ross B. Newman, Ph.D.

Professional Experience:

	2002 - present - Chief Economist, Mitchel Zuniga & Smith, Tustin, CA
	Leader of Transfer Pricing and Economic Consulting Practice. Expanding transfer pricing practice and litigation support practice, developing worldwide network of affiliated tax firms to provide international tax consultation.

1998-2002 - Director of Pacific Region Transfer Pricing Practice, Arthur Andersen, Silicon Valley, CA (West Coast and Western US)

1998-1999 Senior Manager
1999-2002 Partner
Member, Transfer Pricing Oversight Committee, Andersen leadership team of regional Partners. Established Northern California TP group in San Jose. Starting with three staff in LA, the Pacific Region group grew to three teams of economists, with 7 Ph.D.’s and 10 staff economists. Net fees grew from just over one million to over 3.7 million in three years.

1993-1998 Arthur Andersen, New York

   1993-1995 Manager
   1995-1998 Senior Manager
   1996-1998 Chief Economist

Helped establish TP Economics practice, worked on broad range of clients with intangible, inbound and outbound issues for clients in a wide range of industries. Transfer Pricing studies at the state and federal level to resolve tax controversies and for planning purposes to set royalties and as the basis for Advance Pricing Agreements. Worked for a number of Asian and European companies, including general trading companies (sogo shosha) and financial intermediaries, e.g., foreign banks and broker-dealers.

1991-1993 Industry Economist, Internal Revenue Service, 500 North Capital St., Washington, DC

Provided economic expertise in the areas of transfer pricing and the valuation of intangible assets and inventories in IRS audits, support to Treasury and GAO, training (CPE seminars) on §482 to Exam and Appeals and technical support to Chief Counsel on Advance Price Agreements and Tax Court litigation.

	1984-1991	Bentley College, Waltham, Massachusetts - Assistant Professor of Economics. Taught in undergraduate and MBA programs.

	1981-1984	Instructor of Economics, Claremont McKenna College, Claremont, CA. Joint appointment with CMC and Claremont Graduate School. Taught in undergraduate and Ph. D. programs.

	1977	Northwestern University. Teaching Assistant, Robert Eisner and Robert J. Gordon.

	1977-1981	Research Assistant, Robert J. Gordon.

Professional Activities and Seminars

1981 - "Income Taxation and Inventory Pricing" presented at the Social Science Research Council Subcommittee on Monetary Research, Board of Governors Federal Reserve

1983 - Discussant, Western Economic Association Referee, Economic Inquiry

1986 - Discussant, Eastern Economic Association

1987 - Textbook Reviewer, West Publishing Company

1988 - Software Reviewer of textbook ancillaries, Southwestern Publishing Company

1991 - Transfer Pricing Overview, Tax Executives Institute, Hershey, PA

1992 - Transfer Pricing Training, IRS CPE, Cherry Hill, PA

1993 - Transfer Pricing Training, IRS CPE, Philadelphia, PA

1994 - Section 6662 Penalties Seminar, Andersen, New York

1996 - Japanese Trading Companies - Tax Issues, Andersen, New York

1996 - 2001 - Executive Enterprise Institute, Introduction to International Tax, Transfer Pricing Case Study - top-rated speaker

1997 - Intercompany Pricing for Multinationals, Council for International Tax Education, Santa Monica, CA, 'CITE' "Star Award" as top rated speaker

1998 - Seminar on Proposed Section 482 Global Dealing Regulations Andersen, NY

1999 - ASCPA, Asian Tax Developments, San Francisco, CA - Top-rated speaker; TEI and Arthur Andersen, Tax Controversies Seminar, Los Angeles, CA - Top-rated speaker

2000 - Transfer Pricing for Multinational Enterprises, Santa Clara, CACenter for Financial Reporting & Management Hass School of Business, University of California at Berkeley

2001 - Chair, Executive Enterprise Institute, Introduction to International Tax, Seminar

2002 - 12th Annual International Tax Forum, Council for International Tax Education, Santa Monica, CA,

Litigation Support

1991-1992 - Assisted District Counsel and Chief Counsel's with litigation support and Chief Counsel (International) with review of APA's.
1992 - Expert Witness, U.S. Department of Justice, Executive Office for Department of Justice, (mock trial, educational program for U.S. Attorneys), "Examination Techniques: Direct and Cross"
1992 - Author of Expert Witness report for Tax Court
As IRS Economist, Trained Appeals Officers and Senior Revenue Agents "Hazards of Litigation of Transfer Pricing", Philadelphia District, IRS
1995 - Authored Advance Pricing Agreement for Bilateral APA with Japan
1998-2001 - Lead economist on Bilateral APA with Japan
2001 - APA renewal for Bilateral APA with Japan
2002 - Author of Paper on Taxation of Damages from theft of Intellectual Property, looks at damages from perspective of the Civil and Criminal law in California, and related Patent Law and the UTSA (US Trade Secrets Act). This paper corrects a series of errors in the precedents on the tax treatment of damages, and provides a greater basis for tax avoidance.

Education

1976 - B.S. Economics, University of Utah, Salt Lake City, Utah
1987 - Ph.D. Economics, Northwestern University, Evanston, Illinois

Dissertation: Income Taxation and Inventories The tax treatment of inventories under tax law is formally modeled in order to address the impact on firm behavior. The choice of LIFO/FIFO is examined in detail, with an emphasis on their impact on macroeconomic price flexibility and output behavior.

Honors and Awards

University of Utah

1975 - Omicron Delta Epsilon, Economics honorary Vice-president, 1976
1976 - Phi Beta Kappa
1976 - Economics Advisory Committee, Vice-president

Northwestern University
1976 Presidential Fellow
1977 Research/Teaching Fellowship
1978-1979 Research Assistantship
1979 Social Science Research Council Fellowship

Claremont McKenna College
1983 Charter Member, Phi Beta Kappa

Bentley College

1987 - Summer Research Grant
1992 - 2nd Place, BBB, FOVA North American Championship, Columbia, MD., 2-player volleyball on full-size, grass court

Papers:

"Money Demand and Nominal Debt: An Equilibrium Model of the Liquidity Effect" (w/ S. Sumner and O. D. Gulley) Journal of Macroeconomics (20) 2 (1998) pp.267-293.

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Sylvia M. Burroughs, C.P.A.

Professional Experience
	1989 - present - Private practice in accounting, tax compliance and tax controversy. Prepare compiled financial statements. Prepare tax returns for corporations, sub-s corporations, individuals, partnerships, exempt organizations and trusts. Representation before the Internal Revenue Service, Franchise Tax Board and Employment Development Department. 1995 - 1998 - Ernst & Young, Accounting and Tax Accounting Review financial statements. Reconciliation of books and records. Reconciling banks statements. Representation before the Internal Revenue Service, Franchise Tax Board and Employment Development Department. 1967 - 1995 - United States Treasury Department Internal Revenue Agent: Audited large and midsize corporate, individual and partnership returns. District and Appeals Conferee: Resolved and settled audits in lieu of being resolved in Tax Court. General Program Manager: Supervision of 10 to 14 revenue agents. Held informal conferences on un-agreed issues. Large Case Manager: Supervised audits of very large corporations. Specialized in the audits of commercial banks, saving and loans and insurance companies.
Professional Licenses
	1972 - Present: Certified Public Accountant.
Professional Membership
	1973 - Present: Member of the California Society of Certified Public Accountants

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