Tucker Thoni Attorney At Law

Tucker is a shareholder in GrayRobinson’s Orlando office. He focuses his practice on corporate, tax, real estate, and health care matters.

Prior to joining GrayRobinson, Tucker practiced at Sirote & Permutt, P.C. in Birmingham, Alabama, and gained experience in tax and business planning, complex real estate transactions, tax controversies, charitable contributions, conservation easements, landlord/tenant law, partnership law, corporate law, and mergers and acquisitions.

• Education
  • Flagler College, B.A.
    • Dean’s List
  • Florida Coastal School of Law, J.D. (summa cum laude)
    • 3^rd in Class
    • Law Review
    • Dean’s Scholar Award
    • ABOTA Professional Responsibility Scholarship Recipient
  • University of Florida Levin College of Law, LL.M. (summa cum laude)
• Areas of Emphasis
  • Administrative Actions by DBPR
  • Buy/Sell Agreements
  • Charitable Contributions
  • Conservation Easements
  • Commercial Leasing
  • EPA Pathogen List N
  • FDA Registration and Authorization
  • Personal Protective Equipment and other Medical Products Transactions
  • Qualified Opportunity Fund Formation
  • Qualified Opportunity Zone Investments
  • Tax Planning
  • Tax Compliance
  • Tax Controversies
  • Taxation of Partnerships
  • Taxation of C-Corporations
  • Taxation of S-Corporations
• Admissions
  • Florida
  • Alabama
  • U.S. Tax Court
• Professional Associations & Memberships
  • The Florida Bar
  • Alabama State Bar
• Presentations & Seminars
  • “PPE Transactions in a Pandemic: Achieving Compliance and Identifying Fraud," Florida Bar International Law Section, April 22, 2021
  • Florida SBDC Opportunity Zone Workshop Webinar, December 10, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, November 19, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, October 29, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, October 6, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, September 17, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, August 26, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, August 4, 2020
  • "Real Estate, CARES Act, and Tax & Estate Law: The Response to COVID-19," COVID-19 Conversations Webinar Series, June 17, 2020
  • Florida SBDC Opportunity Zone Workshop Webinar, June 16, 2020
  • Opportunity Zone Expo, Miami, Florida, November 14, 2019
  • Opportunity Zones Town Hall, Central Florida Urban League, Orlando, Florida, October 21, 2019
  • Florida Small Business Development Center Network, Pensacola, Florida, October 2, 2019
  • "Adventures in the Land of OZ," American Planning Association Florida 2019 Annual Conference, Miramar Beach, Florida, September 12, 2019
  • JaxChamber Opportunity Zones Conference and Marketplace, Jacksonville, Florida, August 22, 2019
  • "Opportunity Zone Investing," Multifamily Investing Meetup, Orlando, Florida, July 23, 2019
  • "Hot Topics from 1st Set of Opportunity Zone Treasury Regulations” Miami-Dade Opportunity Zones Conference & Marketplace, Madison Street Strategies, Miami, FL, April 8, 2019
  • “Tax Benefits of Investing in Opportunity Zones,” Madison Street Strategies Opportunity Zones Workshop, Tallahassee, FL, March 14, 2019
  • "Conservation Easements: Defending IRS Challenges, Overcoming Audits, Structuring Deed Language for Perpetuity," Strafford Webinar, September 13, 2018
  • "Employment Tax: Unlocking the Mystery,” Birmingham Chapter American Payroll Association, June 15, 2017
• Articles & Publications
  • Co-author, "Navigating PPE Transactions During a Global Pandemic," International Law Quarterly, October 2020
  • “Pandemic Extensions May Save Opportunity Zone Investment," Law360, June 2020
  • "Unpacking The Final Opportunity Zone Regulations: Part 2," Law360, January 2020
  • "Unpacking The Final Opportunity Zone Regulations: Part 1," Law360, January 2020
  • "Opportunity Zones are Meant for the Poor. But They Could Help Rich Orlando, Winter Park Areas, Too," Orlando Sentinel, November 2019
  • "4 Working Capital Safe Harbors For QOZ Startups," Law360, August 14, 2019
  • "IRS Takes Uncharitable View Of Property Donation Deductions," Law360 Tax Authority, August 22, 2018
  • "Top 6 IRS Attacks On Conservation Easement Deductions," Law360 Tax Authority, July 5, 2018
  • "Tax Court Disallows Developer's $11,040,000 Charitable Deduction: Characterizes PUD Plan Approval Process as Quid Pro Quo Arrangement," Conservation Easement Blog, June 18, 2018
  • "IRS Warns States and Taxpayers in New Notice Addressing Charitable Contributions that Produce Both Federal Tax Deductions and State Tax Credits," Tax Planning Blog, June 14, 2018
  • "Tax Court holds that Donor Receipt of a Substantial Benefit Disallows a Charitable Deduction," June 13, 2018
  • "Confusion Following the Death of the Conservation Easement 'Enhancement Regulation'," Conservation Easement Blog, April 11, 2018 
  • "Taxpayer Notice: IRS Interest Rates are Increasing on Refunds and Deficiencies," Tax Controversy Blog, March 13, 2018
  • "House and Senate Agree on Terms of Tax Cuts and Jobs Act of 2017," December 18, 2017
  • "Tax Court and Second Circuit Disagree on What Amounts to Timely Managerial Approval of Penalties: Chai v. Comm'r, 851 F.3d 190 (2nd Cir. 2017) versus Graev v. Comm'r, 147 T.C. No. 16 (2016)." Tax Controversy Blog, November 13, 2017
  • "The Tax Cuts and Jobs Act of 2017," Tax Planning Blog, November 2, 2017
  • "Can RERI Holdings I, LLC Co-Exist with Existing Tax Court Precedent Regarding Conservation Easement Donations?" Conservation Easement Blog, October 24, 2017
  • "Update on Hurricanes Irma, Harvey, and Maria Disaster Relief: The IRS has a Change of Heart Regarding the Filing Deadlines for IRS Form 8886." Tax Controversy Blog, October 2, 2017
  • "Listed Transaction Update: Hurricane Disaster Relief Does NOT Extend the October 2, 2017 Deadline to File IRS Form 8886." Tax Controversy Blog, September 28, 2017
  • "RERI Holdings I, LLC: The Tax Court Changes Course Regarding Substantial Compliance with IRS Form 8283." Conservation Easement Blog, August 31, 2017
  • "RERI Holdings I, LLC: What the Basis?" Conservation Easement Blog, August 28, 2017
  • "For Whom the Statute Tolls? The IRS." Conservation Easement Blog, June 5, 2017
  • "Taxpayers Required to File Form 8886 for Listed or other Reportable Transactions: the IRS demands its Form over substance," Conservation Easement Blog, May 25, 2017
  • "Conservation Easement Listed Transactions," Conservation Easement Blog, April 28, 2017
  • "Fluctuating Workweek Affects Overtime Pay and Retail Data Breach Not Insured," Conservation Easement Blog, November 3, 2016
• Media Mentions
  • "Windows of Opportunity," Corporate Counsel Business Journal, January 6, 2020
  • "Large Turnout to Learn About 'Opportunity Zones' in Tallahassee," Tallahassee Democrat, March 18, 2019
• Civic
  • Leadership Seminole, Class 30