Bio
Prior to joining PilieroMazza’s Litigation & Dispute Resolution Group, Paul served as a senior attorney with the Department of Justice. He is a seasoned litigator and appellate attorney with over 25 years of experience representing businesses and government entities in complex disputes, with a particular focus on government contracting, tax controversy, and government investigations. At PilieroMazza, Paul advises clients on high-stakes litigation involving federal procurement, regulatory compliance, tax controversy disputes, and enforcement matters. He brings deep knowledge of the federal legal landscape, courtroom experience at every level of the judiciary, and a practical understanding of the regulatory challenges that government contractors and private-sector companies face.
As lead counsel in more than 100 appeals across every U.S. Circuit Court of Appeals, Paul addressed matters involving constitutional, tax, and administrative law issues central to government contractors, as well as intricate statutory and regulatory regimes. He has argued dozens of appeals and authored U.S. Supreme Court briefs at both the certiorari and merits stages—appearing for both principal parties and as amicus curiae.
Paul also has extensive experience at the trial level, having served as lead or co-lead counsel in dozens of matters before U.S. District and Bankruptcy Courts. Notably, he tried complex, multi-week cases involving sophisticated tax shelter structures and high-value federal enforcement actions—experience that translates into effective courtroom advocacy for PilieroMazza’s government contractor clients facing False Claims Act allegations, audits, suspension and debarment proceedings, and contract disputes.
Before entering public service, Paul practiced at a national law firm, where he worked on trial teams in complex commercial litigation. That work spanned antitrust, corporate insurance recovery, internal investigations, and white-collar defense, including the False Claims Act—areas that continue to impact companies operating in the highly regulated government contracting space.
Related Practice Areas
Representative Matters
Representative Appellate Matters:
- Peter E. McGowan, et al. v. United States, No. 24-3228 (6th Cir.) (pending) (validity of “split-dollar” life insurance regulation (26 C.F.R. § 1.61-22) in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024), and propriety of “restricted property trust” life-insurance transaction).
- Sirius Solutions, L.L.L.P. v. Commissioner, No. 24-60240 (5th Cir.) (pending) (interpretation of the term “limited partner” for purposes of the exception from self-employment tax in 26 U.S.C. § 1402(a)(13)).
- RSBCO v. United States, 104 F.4th 551 (5th Cir. 2024), cert. denied, 2025 WL 76488 (2025) (reversal of jury verdict against United States regarding imposition of $500,000 penalty pursuant to 26 U.S.C. § 6721 for failure to timely file information returns as required by 26 U.S.C. § 6045 and imposition of attorney’s fees).
- Delek US Holdings, Inc. v. United States, 32 F.4th 495 (6th Cir. 2022) (taxpayer denied $16-million deduction for fuel excise taxes after it improperly sought to include $64 million in renewable-fuel credits (26 U.S.C. § 6426) in its cost of goods sold).
- United States v. Bittner, 19 F.4th 734 (5th Cir. 2021), rev’d, 598 U.S. 85 (2023) (calculation of non-willful penalties under 31 U.S.C. § 5321 for failure to file FBARs as required by 31 U.S.C. § 5314) (Briefed and argued in Fifth Circuit; drafted brief in Supreme Court).
- Bedrosian v. United States, 42 F.4th 174 (3d Cir. 2022), cert. denied, 143 S. Ct. 2636 (2023) (affirming the applicable standard for willfulness in the context of penalties under 31 U.S.C. § 5321 for failure to file FBARs and calculation of statutorily maximum permissible penalty).
- Robb Evans & Assocs., LLC v. United States, 850 F.3d 24 (1st Cir. 2017) (court-appointed receiver for consumer credit counseling agency that perpetrated massive consumer fraud not entitled to $10 million deduction pursuant to 26 U.S.C. § 1341 (claim of right) for amounts agency had previously obtained as a result of the fraud and reported as income).
Representative Trial Matters:
- Citizen Awareness Project, Inc. v. IRS, No. 13-cv-2127-WJM-NYW, 2015 WL 2155723 (D. Colo. May 6, 2015) (partial summary judgment and denial of punitive damages under 26 U.S.C. § 7431 as a result of an unlawful disclosure of an entity’s application for recognition of tax-exempt status, in connection with allegations of unlawful targeting of conservative political groups by the IRS).
- Kearney Partners Fund, LLC v. United States, (M.D. Fla. 2011) (government victory following 8-day trial; taxpayer not entitled to deduction based on $77 million loss generated through abusive tax-shelter transaction executed through sham foreign-currency transactions).
Insights
News
Credentials
Education
- Georgetown University Law Center, J.D., 1997, magna cum laude
- University of Maryland, Baltimore County, B.A., 1988
Admissions
- District of Columbia
- Maryland
- U.S. Supreme Court
- U.S. Court of Federal Claims
- U.S. Court of Appeals, District of Columbia Circuit
- U.S. Court of Appeals, First Circuit
- U.S. Court of Appeals, Second Circuit
- U.S. Court of Appeals, Fourth Circuit
- U.S. Court of Appeals, Fifth Circuit
- U.S. Court of Appeals, Seventh Circuit
- U.S. Court of Appeals, Ninth Circuit
- U.S. Court of Appeals, Tenth Circuit
- U.S. Tax Court