Christina Novotny

Counsel

Cleveland
T +1.216.861.7295
F +1.216.696.0740

Overview

Christina Novotny is a tax attorney whose practice focuses on the federal tax treatment of real property transactions, specifically including transactions involving partnerships, federal and state historic rehabilitation tax credits, federal and state new markets tax credits, and Section 1031 tax-deferred exchanges. A former Big Five accounting firm CPA, she has the technical knowledge and experience to navigate tax issues and apply creative structuring solutions to solve problems her clients face.

Select Experience

Historic Tax Credits
  • Represented a developer with respect to an approximately $40 million rehabilitation and repurposing of a historic structure in Pittsburgh into a residential rental complex. Structuring needed to address both federal and Pennsylvania historic preservation tax credits as well as a state grant.  
New Markets Tax Credits
  • Represented a community development entity (CDE) with respect to its involvement in a $50 million conversion of a historic structure in northwest Ohio into a corporate headquarters.
Section 1031 Transactions
  • Regularly assists firm clients with tax-deferred Section 1031 exchanges (including reverse and multiple property exchanges). Such assistance includes drafting and reviewing documents (including exchange agreements, qualified exchange trust agreements, qualified exchange accommodation agreements, identifications and notices) and advising on structures (including tenancy-in-common structures). Recent representative experience includes serving as tax counsel for an approximately $45 million deferred like-kind exchange involving an Ohio shopping mall and setting up an approximately $46 million reverse exchange involving a Texas office property.
Real Estate Tax Planning
  • Provided advice to high-wealth individuals on the proposed division of multiple properties held in various family partnerships valued at more than $15 million to achieve desired restructuring in a tax-efficient manner.
Tax Settlement
  • Assists taxpayers with settling outstanding tax debt with the IRS and the state of Ohio, specifically including filing and negotiating Offers in Compromise and Installment Agreements. Recent representative experience includes settling taxpayer's IRS debt for approximately 10 percent of the amount due and state of Ohio debt for approximately 40 percent of the amount due.
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Experience

Historic Tax Credits
  • Represented a developer with respect to an approximately $40 million rehabilitation and repurposing of a historic structure in Pittsburgh into a residential rental complex. Structuring needed to address both federal and Pennsylvania historic preservation tax credits as well as a state grant.  
  • Served as tax counsel to a private university located in the Midwest in connection with the approximately $42 million historic rehabilitation of its sports arena. The engagement involved the "lease pass-through" model and sophisticated structuring resulting from the participation of exempt organizations.
  • Assisted a developer client in navigating the changing Ohio historic rehabilitation tax credit regime to maximize the state tax credit equity resulting from multiple rehabilitation projects. The engagement included working with state of Ohio tax departments and agencies to advance the client's interests.
New Markets Tax Credits
  • Represented a community development entity (CDE) with respect to its involvement in a $50 million conversion of a historic structure in northwest Ohio into a corporate headquarters.
  • Assisted a Cleveland nonprofit performing arts center in the acquisition and rehabilitation of a historic office building. The approximately $41.5 million project was financed with the assistance of federal and state new markets tax credits, as well as federal and state historic rehabilitation tax credits. The deal involved four different closings with three different CDEs. Assisted with structuring, advised on financial projections and drafted required tax opinions.
Energy Tax Credits
  • Member of a team that served as tax counsel to an insurance company in connection with its investment in a solar energy facility, which is anticipated to generate more than $40 million in energy tax credits.
Section 1031 Transactions
  • Regularly assists firm clients with tax-deferred Section 1031 exchanges (including reverse and multiple property exchanges). Such assistance includes drafting and reviewing documents (including exchange agreements, qualified exchange trust agreements, qualified exchange accommodation agreements, identifications and notices) and advising on structures (including tenancy-in-common structures). Recent representative experience includes serving as tax counsel for an approximately $45 million deferred like-kind exchange involving an Ohio shopping mall and setting up an approximately $46 million reverse exchange involving a Texas office property.
Real Estate Tax Planning
  • Provided advice to high-wealth individuals on the proposed division of multiple properties held in various family partnerships valued at more than $15 million to achieve desired restructuring in a tax-efficient manner.
Tax Settlement
  • Assists taxpayers with settling outstanding tax debt with the IRS and the state of Ohio, specifically including filing and negotiating Offers in Compromise and Installment Agreements. Recent representative experience includes settling taxpayer's IRS debt for approximately 10 percent of the amount due and state of Ohio debt for approximately 40 percent of the amount due.

Recognitions and Memberships

Memberships

  • Tax Club of Cleveland
  • American Bar Association
  • Ohio State Bar Association
  • Cleveland Metropolitan Bar Association

Community

  • Notre Dame Club of Cleveland Lawyers Alumni Committee: Executive Council

Pro Bono

  • Represented a local woman whose wages were being garnished by the IRS. Obtained "Innocent Spouse Relief" on her behalf in an amount close to $12,000 (back taxes plus interest).
  • Legal Aid Brief Advice Clinic Organizer

Emerging Issues

Admissions

  • U.S. Tax Court, 2008
  • U.S. District Court, Northern District of Ohio, 2008
  • Ohio, 2007

Education

  • J.D., Notre Dame Law School, 2007, magna cum laude
  • B.B.A., Accounting, Ohio University, 1999, summa cum laude
  • B.A., Spanish, Ohio University, 1999, summa cum laude