Kenneth W. Gideon’s practice focuses on three often overlapping areas: representation of clients before the U.S. Department of the Treasury and the Internal Revenue Service; seeking guidance on novel transactions; and issues of federal tax law, tax controversy and tax planning. Mr. Gideon serves as one of the leaders of the firm’s national Tax Litigation Practice. Mr. Gideon advises clients on a wide variety of guidance, controversy (including tax litigation) and planning matters. In the guidance area, he has assisted clients in obtaining published guidance in the form of regulations, revenue rulings and revenue procedures. In addition, he has assisted in obtaining numerous private letter rulings and closing agreements. Mr. Gideon has advised clients in connection with numerous corporate mergers, acquisitions and restructurings, particularly in situations in which the transaction may require a ruling or informal discussion with the Internal Revenue Service.