As a former trial attorney for the Internal Revenue Service, Sue Ann focuses her practice on advising and representing clients in all facets of federal and state tax administrative proceedings (audits and appeals), criminal tax investigations, and tax litigation before the state and federal courts.
Sue Ann is a shareholder and officer in Fredrikson & Byron’s Tax Disputes & Litigation and Agribusiness Groups. Her results-oriented representation of individuals, corporations, estates, cooperatives, financial institutions, and trusts has produced favorable resolutions before the IRS and state taxing authorities, many of which have been successfully concluded without the need for litigation.
In addition to her tax controversy work with clients, Sue Ann dedicates a significant portion of her practice counseling and advising agricultural and rural electric cooperatives on tax issues unique to their industry groups.
Astleford v. Commissioner, T.C. Memo 2008-12 (gift tax case involving valuation of gifts of interest in a family limited partnership – three tiers of discounts approved by court)
Chapman v. Commissioner, 651 N.W. 2d 825 (Minn. 2002): Minnesota alternative minimum tax provision limiting charitable contribution deductions to only Minnesota charities declared unconstitutional as discriminatory to interstate commerce
Northern States Power Company and United Power Association v. Commissioner, 571 N.W. 2d 573 (Minn. 1997): Minnesota sales tax exemption for capital equipment held applicable to electrical transformers located outside power plants (ruling later extended to power lines and poles)
O’Shaughnessy v. United States, 517 N.W. 2d 574 (Minn. 1994): Federal tax lien held unenforceable against assets of discretionary trust
Burlington Northern Railroad Company v. Commissioner, 509 N.W. 2d 551 (Minn. 1993): Minnesota sales tax imposed on railroad rolling stock held invalid under federal 4-R Act
Landmark v. U.S., 25 Cl. Ct. 100 (1992): First case in the country to hold that cooperatives are not subject to the deduction limitations of I.R.C. Section 277
Security Bank Minnesota v. Commissioner, 98 T.C. 33 (1992), aff’d, 994 N.W. 2d 432 (8th Cir. 1993): Tax case that involved 40 Midwestern banks holding that small cash-basis banks were not subject to the interest accrual rules under I.R.C. Section 1281
Member, Past Chair, Tax Section, Minnesota State Bar Association
Executive Committee Chair, Legal Tax & Accounting Subcommittee, National Council of Farmer Cooperatives (2003-2004)
Past President, National Society of Accountants for Cooperatives, North Central Chapter