Services
Industries
Education
Columbia Law School, LL.B.
Wayne Law School, LL.M., 1965 Taxation
Columbia College, A.B. 1962
Bar Admissions
- Michigan
- New York
When it comes to tax issues, Loren Opper is widely recognized as one of the leading legal experts in the United States with an extensive prior background in both the private and public sectors.
During a more than 35-year career at Ford Motor Co., most recently as director of IRS Audits, Appeals and Litigation, Loren was responsible for handling all of the automaker's complex federal tax issues. Currently his practice focuses on federal tax controversies, including income and employment taxes in the federal courts and matters within the Internal Revenue Service, including examinations and administrative appeals.
Reported and Published Decisions
Ford Motor Company v Commissioner, 102 T.C. 87 (1994), aff'd, 71 F.3d 209 (1995)
Ford Motor Company v Michigan State Tax Commission, 255 N.W.2d 608 (Mi. Sup. Ct. 1977)
Ford Credit Michigan Titling Trust, et al. v Michigan Department of Treasury (Mich. Cl. Ct. No. 09-3-MT)
Kmart Corporation v Michigan Department of Treasury (Mich. Ct. App. No. 282058)
Masco Corporation v Michigan Department of Treasury (Mich. Cl. Ct. No. 07-64-MT-C30)
Pending
Ford Motor Company v Michigan Department of Treasury (Mich. Cl. Ct. No. 06-104-MT)
Ford Motor Company v Michigan Department of Treasury (Mich. Cl. Ct. No. 06-3-MT)
Ford Motor Company v Michigan Department of Treasury (Mich. Ct. App. No. 283935)
Broz v Commissioner (Court of Appeals for the Sixth Circuit (2012))
Honors
State Bar of Michigan Pro Bono Honor Roll, 2022
Professional Activities
State Bar of Michigan
New York State Bar
Detroit Chapter, Tax Executives Institute, Chapter President, 2000-2001; Chapter Director
Tax Executive Institute's Meritorious Service Award
Material contributions to comments by the Tax Executives Institute concerning regulations relating to the definition of qualified research activities and other matters affecting computation of the research tax credit under IRC sec. 41 (2001)
Material participation in the preparation of comments by the Tax Executives Institute concerning IRS Notice 99-50, Ex Parte Communications between IRS Appeals Officers and other IRS Employees (1999)
Material participation in the preparation of comments by the Tax Executives Institute concerning IRS Notice 98-31, Service-Initiated Accounting Method Changes (1998)
Civic, Cultural & Social Activities
Accounting Aid Society, Preparation of tax returns for low-income individuals
Teaching
Wayne State University Law School, Adjunct Professor, State and Local Taxation, 1975-1990
Walsh College, Adjunct Professor, Federal and State Taxation, 1973-1990
Speeches
"Accountant-client Privilege," Michigan Association of Certified Public Accountants, November 2012
"Federal Legislation Affecting State Tax Matters," Tax Executives Institute, Detroit Chapter, 2012
"Alternative Minimum Tax: Causes & Calculations Pitfalls & Planning," Michigan Association of Certified Public Accountants, June 20, 2012
"MBT to CIT: Lingering Issues & What is Coming Down the Pike," Michigan Association of Certified Public Accountants, June 12, 2012
"National State and Local Tax Developments," Tax Executives Institute, Detroit, Michigan, March 21, 2012
"Sales and Use Tax Audits," Michigan Association of Certified Public Accountants, December 15, 2011
"Michigan’s New Corporate Income Tax," Michigan Association of Certified Public Accountants, November 9, 2011
"IRS Compliance Assurance Process," Panelist, American Bar Association Tax Section Fall Meeting, October 2011
"FIN 48 and issues related to the Michigan Tax," Michigan Tax Conference, November 2010
"Worker Classification for Tax Purposes," Michigan Women's Tax Association and Tax Executives Institute, Detroit Chapter, 2010
"Texas Margin Tax and Michigan Business Tax: What Lessons Can We Learn?," Panelist, Detroit Chapter Tax Executives, January 2009
"Business Purpose and Economic Substance" and "Preparer Penalty Amendment," Pending Federal Tax Legislation, Michigan Tax Conference, November 2008
"Michigan Business Tax," Council on State Taxation's Mid-West Regional State Tax Seminar held jointly with the Multistate Executives Tax Roundtable, October, 2008
"The IRS Compliance Assurance Policy," Tax Executives Institute Panel Discussion, 2007
"Federal Income Tax Credit for Research Expenses for Automotive Suppliers," Original Equipment Suppliers Association, 2007
"FIN 48, Early Resolution and Achieving Currency; Raising and Resolving Issues on a Consistent Basis; Research Credit," Moderator, IRS-Tax Executives Institute Issue Discussion Forum, 2007
"FIN 48 and Multi-State Tax Issues," Michigan Tax Conference, 2007
"FIN 48 - Best Practices and Lessons Learned," Paul J. Hartman Forum, 2007
"IRS-TEI Town Hall Meeting to Discuss New Large and Mid-Size Business Organization," Moderator, 2000
"Automotive & Related Suppliers - Recent Tax Developments," Moderator, Tax Executives Institute Annual and Mid-Year meetings, numerous years
Publications
"Flawed Analysis Supports Common Law Tax Deficiency Ruling" (co-authored with Christie Galinski), Law360, July 11, 2023
"Private Entity Participation in Legislation: Justice Alito and the CAMT," Tax Notes State, Jan. 9, 2023
"Did Congress Unconstitutionally Delegate Taxing Power in the Inflation Reduction Act of 2022 to a Private Entity?", Tax Notes, Jan. 9, 2023
"Compliance Assurance Process," The Tax Executive, Vol. 63, No. 6, November-December 2011
"Research Credit for Manufacturing & Assembly Plants - Is the credit available? It all depends," Hot Points, Summer 2008
"Michigan State and Local Tax Review," American Bar Association
"State & Local Taxation," 24 Wayne Law Review 629, 1978
"State and Local Taxation," Stanley, Tunstall, Opper, 23 Wayne Law Review 851, 1977
"Constitutional Aspects of the Single Business Tax," 22 Wayne Law Review, 1976
"State and Local Taxation," Stanley, Tunstall, Opper, 22 Wayne Law Review, 1976
"State and Local Taxation," Stanley, Tunstall, Opper, 21 Wayne Law Review, 1975
"State and Local Taxation," Stanley, Tunstall, Opper, 20 Wayne Law Review, 1974
