Prior to joining Cantor & Webb, Ms. Leibowitz spent three and a half years with the Internal Revenue Service, Office of Chief Counsel, in Washington, D.C. During her time at the Office of Chief Counsel, Ms. Leibowitz authored a number of items of published guidance, including private letter rulings, chief counsel notices, regulations, and revenue rulings. Highlights include: Revenue Ruling 2006-34, providing guidance of safe harbors and a list of factors that are likely to be relevant in determining whether a deceased owner's activities with regard to certain real property were sufficiently active to support a finding that the real property interest constitutes a closely held business interest for purposes of section 6166; Treasury Decision 9229, Regulations under Section 6081, providing guidance relating to the simplification of procedures for obtaining automatic extensions of time to file certain return; Treasury Decision 9215, Regulations under Section 6020, providing guidance when a taxpayer fails to file a return, the methods by which the IRS may prepare a return on the taxpayer's behalf; Revenue Procedure 2005-33, providing guidance on exhausting administrative remedies prior to seeking a declaratory judgment under section 7479 when an executor has made an election under section 6166 to extend the time for payment of tax with respect to an interest in a closely held business.

Born and raised in Miami Beach, Florida, Ms. Leibowitz was admitted to the Florida Bar in 2001 and the United States Tax Court Bar in 2002. Ms. Leibowitz is a member of the Tax Section of the Florida Bar.

Education:

• Bachelor of Arts in English, Georgetown University, 1998
• Law Degree, cum laude, from the American University, Washington College of Law, 2001
• American University, Washington College of Law, Administrative Law Review, Member
• Master of Laws in Taxation, with a certification in International Tax, University of Miami School of Law, 2006

Tracey B. Leibowitz is an associate specializing in international taxation and estate planning.

Bar/Court Affiliations:

• Florida Bar
• United States Tax Court