Overview

Jenny represents clients in all types of tax disputes and controversy, including federal and state audits, administrative appeals, and litigation. She also provides tax advice to renewable energy companies, with a focus on the state and local level.

Jenny assists her clients on a variety of tax matters, including the following:

  • Tax Disputes & Litigation
    • State Corporate Income and Franchise Taxes, including nexus, Public Law 86-272, business versus non‑business income, apportionment, and federal preemption;
    • Federal Corporate Income Taxes, including trade or business expenses (e.g. reasonable compensation, travel, substantiation), penalty abatement (including accuracy-related penalties and fraud), and offshore financial asset disclosures;
    • Employment and Withholding Taxes, including worker classification audits and appeals, penalty abatement, withholding requirements for companies with international and nonimmigrant employees, and Form 5500 delinquent filings;
    • Sales and Use Taxes, including exemptions (e.g. direct mail, advertising, materials used to construct renewable energy facilities), nexus, sourcing, marketplace provider obligations, bundled transactions, and voluntary disclosures;
    • Individual Income Taxes, including passive/active loss issues, hobby losses, automated underreporting issues, offshore financial asset disclosures and streamline filings, exit tax, and collection matters.
  • Renewable Energy Taxes, Jenny advises renewable energy developers (utility-scale wind and solar projects, community solar, transmission, storage, etc.) on state and local taxation, including preparing property tax modeling, transactional advice, and tax opinions. She also helps clients navigate conversations with local governments regarding the tax benefits of a project.
  • Property Tax Appeals, including valuation and appeals of real and personal property (including commercial and state-assessed property). Jenny also advises clients on federal and state tax issues regarding conservation easements, including procedural and reporting issues.

Jenny serves clients from a variety of industries including, retail, construction, manufacturing, computer software, healthcare, financial services, restaurants, entertainment, energy, renewable energy and carbon credits. Additionally, Jenny represents pro bono clients on tax matters and immigration and asylum matters.

Services

Credentials

Education

  • University of Wisconsin Law School, J.D., 2014
  • Gustavus Adolphus College, B.A., 2009, magna cum laude

Admissions

  • Minnesota, 2014
  • Wisconsin, 2014
  • U.S. Tax Court, 2020

Clerkships

  • Judicial Law Clerk, Minnesota Tax Court, 2015-2017

Recognition

  • Best Lawyers: Ones to Watch, Tax Law, 2022-2024
  • North Star Lawyer, Minnesota State Bar Association, 2019-2022

Civic & Professional

Professional Activities

  • American Bar Association, Taxation Section
  • Minnesota State Bar Association, Tax Law Section, Council Member 2021-present
  • Member, Institute for Professionals in Taxation

Community

  • Southern Minnesota Regional Legal Services (SMRLS), 2016-present
  • Gustavus Adolphus College Mentoring Program, Mentor, 2016-2018

News & Insights

Publications & Presentations

"A Great Time to be Green: Top 10 Federal Tax Incentives Under the Inflation Reduction Act," co-authored with William Howieson, MNCPA Footnote, August//September, 2023

Co-Presenter with Masha Yevzelman, What to Know About Worker Classification: Independent Contractor v. Employee, 2022 Tax Institute, Minneapolis, MN, December 12, 2022

Co-Presenter with Lynn Linné, Discussion of State Tax Cases, Issues and Policy Matters to Watch, Council on State Taxation Mid-West Regional State Tax Seminar, Richfield MN, September 22, 2022

"A Primer on State and Local Taxation of Utility-Scale Wind and Solar Projects," American Bar Association, August 30, 2022

Co-Presenter, Conservation Easement Donations: Great for the Environment, Thorny for Taxpayers, Fredrikson & Byron Webinar, March 18, 2021

Co-Presenter, Something Different: An Income Tax “Potpourri” Webinar, Fredrikson & Byron and RSM Webinar, December 10, 2020

Co‑Presenter, Innovative Audit Challenges: Mitigating Revenue Department Assessment Strategies, The State Tax Webinar Series, MNCPA & Fredrikson & Byron, P.A., May 7, 2020

Co‑Presenter, Getting to the Truth: Fundamentals of Discovery & Public Records for SALT Lawyers, American Bar Association Taxation Section Midyear Meeting, January 30, 2020

Co‑Presenter, Current Developments in the Mid-West States, COST 2019 Mid-West Regional State Tax Seminar, September 19, 2019

“Urban Struggles: An Analysis of Title IX and Urban High School Athletic Opportunities for Girls,” 29 Wisconsin Journal of Law, Gender & Society 2, 2014

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