Director of Tax Research
Jenny Massanelli, Director of Tax Research, Attorney
Location: Little Rock, Arkansas
Direct Line: 501.975.0142
Area of Specialty: Food and Agriculture; Estate Planning
Education: B.A. with distinction in Philosophy and English, University of Virginia; J.D. with honors, Bowen School of Law, University of Arkansas at Little Rock; LLM with distinction in Taxation, Georgetown University Law Center.
Currently engaged as the Director of Tax Research, Jenny brings an extensive background in legal research and writing.
Since joining Frost in 2012, Jenny has focused her practice on animal agriculture, business and commercial transactions, tax planning and estate planning. Her work with the IRS and USDA regarding agriculture is groundbreaking and provided our clients with a marked advantage over the competition.
Jenny served as an Associate Notes Editor on the University of Arkansas at Little Rock Law Review, where her Law Review Note was published, and as Symposium Editor for the Journal of Taxation at Georgetown University Law Center. Her writing has been featured in publications for the Arkansas Bar Association and the Midwest Poultry Consortium.
- Licensed to practice law in Arkansas and Virginia; admitted to practice before the Eastern and Western District Courts of Arkansas and the Eighth Circuit Court of Appeals
- American Bar Association
- Arkansas Bar Association
- Virginia Bar Association
- Pulaski County Bar Association
- Arkansas Supreme Court Client Protection Fund Committee
- Georgetown Alumni Interview Program
Passions and Interests:
Other than work, I enjoy traveling, reading, and running.
Q & A with Jenny Massanelli
What is it about tax law that first drew your interest?
My interest in tax law started with my first estate planning class and a clerkship during my second year of law school. I knew early on that I wanted to be a transaction attorney rather than a litigator or someone who spends a lot of time in court, but I didn’t know in which area I wanted to focus or specialize. While serving as a clerk at a local firm, one of the attorneys I worked for suggested that I get my LLM (masters in law) in tax if I was interested in estate planning. That, in turn, led me to apply to the LLM programs at Florida, NYU, and Georgetown, with Georgetown being my first choice. I originally intended to get a certificate in estate planning from Georgetown, but once I saw the class program and all the different areas of tax law, I decided to focus more on corporate, partnership, and nonprofit tax law.
As a practicing attorney, I enjoy the challenges that come with primarily focusing on the Internal Revenue Code. Using the Code for the benefit of our clients becomes something like a game, and I am at my happiest and most engaged when I am grappling with a complex issue or trying to think of a way to get from point A to point B when most people would tell you that you can’t get there.
What’s it like working for Frost?
It’s challenging and thrilling and engaging and always different. It’s much different from working in a traditional law firm, where the pace can be slower, certain practices are antiquated, and traditions are hard to change. At Frost, on the other hand, we are encouraged to think creatively and to push boundaries. For example, when I first started working here and was reviewing a form contract for a client, I didn’t make any changes to the substantive language of the document. The partner I was working for said you should always look for ways to improve, even if what you are reviewing is something that’s been used before. What makes a document so precious or sacred that it can’t be tweaked or finessed? Unless it’s specific tax language that is relevant to the client, then nothing. Everything is open for improvement. That sort of mindset is not always present in a traditional law firm.
What’s the most dramatic change that you’ve seen in our industry?
The most dramatic change I’ve seen with respect to the legal industry is the push for individuals to take care of legal matters themselves rather than relying on an attorney. Websites like LegalZoom, RocketLawyer, and Nolo take tasks that have traditionally been handled by attorneys, such as setting up LLCs and drafting wills and trusts, and put them in the hands of the individuals themselves. Although these online self-help tools are convenient and offer a lower-cost option, the danger is that the individual does not get custom-tailored services, there is no guarantee that someone with the necessary experience is offering informed guidance, and there is no guarantee as to the quality of the work delivered. And these tools aren’t necessarily easy to use, which widens the margin for user error. I have a client who tried to set up an LLC online through LegalZoom, and she ended up contacting me for help because the online tool was too confusing. These online services are also one of the reasons that law firms are hiring less attorneys out of law school and why it is harder for a new attorney to go out on his or her own. And there’s no reason to believe that this trend will slow down. Attorneys, law firms, and law schools will need to get more creative in marketing legal services and in preparing future attorneys for a changing market.
Describe your most memorable Frost moment.
My most memorable moment came shortly after joining Frost. My first big assignment was to show how the Farm Service Agency (FSA) was wrong in its characterization of a client’s W-2 wages received from the client’s work on his family farm. The client labelled the wages as farming, whereas the FSA labelled the wages as non-farming. The FSA’s argument was primarily based on a footnote in the FSA’s own handbook, which footnote stated that W-2 wages were not farming. At stake was the client’s eligibility for FSA program payments; if the wages were farming, then the client qualified for program payments, but if the wages were non-farming, then the client would be disqualified. Early on in the case I contacted some of the attorneys at the law firm where I worked prior to joining Frost, and each one of them said we had a loser of a case. It was an uphill battle from the beginning.
We took the FSA’s determination that the wages were non-farming to the FSA National Appeals Division (NAD), and we won. Then the FSA then appealed the NAD decision and requested Director Review, and we won again. I remember barely being able to read the opinions when they came out, I was so excited about our success.
What motivates you?
The desire to learn new things, the desire to serve my clients’ needs, and the desire to win.
What is the funniest thing that has happened to you recently?
One weekend last summer my husband and I were doing a long run through Downtown Little Rock in the heat of the day and we stopped to take a break in the shade of a building. We were sitting down in a doorway when this minivan pulls up on the street in front of us. The driver rolled down her window, stuck her head out, and asked if we were homeless. I’m sure I looked like a wreck, but come on!
Why do customers choose Frost?
I think customers choose Frost because we can provide them with a level of service and expertise that is unmatched in our region. We have a team of dedicated people who are willing to travel to where the clients are and engage clients at industry events. It’s more than about simply providing legal or accounting services, however. There are accountants and attorneys all over who sit in their offices and simply provide a service. Clients choose Frost because they see our passion and our drive and know from experience that we will go the extra mile for them. We also provide a full range of services for our clients and can provide a high level of expertise to any client anywhere in the country. The ability for a client to tap into our wide range of resources at any time provides another huge incentive to clients.
Does your work relate to any experiences or studies you had in college?
When I interviewed at Frost, one of the questions I was asked was why I wanted to work for an accounting firm when I didn’t have any accounting experience. Although my college classes on utilitarianism or the Victorian novel or modern literary theory do not come into play during my professional career, my classes in English and philosophy taught me to think more creatively and provided me with a firm background in persuasive writing, reading critically, and analytical thinking.
A Little More About Jenny
Michael Clayton, Lost in Translation, Kill Bill, Fargo, The Departed
Books currently reading:
I am currently wrapping up Stephen King’s Dark Tower series. I’m not quite sure what I’ll turn to once I’m finished, although I always have a long list of books I want to read. I try to bounce back and forth between different genres and literary periods so that I’m reading different perspectives, but my favorite literary genre is postmodernism. You could also say I’m currently reading Swann’s Way by Marcel Proust. I started it a while ago and took a break from it when I got halfway through to read something else, but that break never ended. At this point I’ll probably just reread it from the start. There are only two other books that I have started reading but have been unable to finish: Ulysses by James Joyce and The Recognitions by William Gaddis.
I think every accountant/tax attorney should read The Pale King by David Foster Wallace, which is set in an IRS office in the Midwest. The novel is unfinished, but Wallace’s descriptions of government bureaucracy, the dreary hopelessness of government work, and the IRS in general are pretty hysterical.
Relax when not working:
If I’m not at the office or working, I’m probably either running or reading. I started running local 5ks in 2011 and have been racing and training ever since. I’ve run the Boston Marathon twice and have qualified for a third time. I’ve run a total of 43 races at the marathon distance or longer, including a number of 50ks, a 50 miler, and a 100 miler. My husband and I got married in Central Park in New York City, and three days before the wedding we ran the Brooklyn Marathon together in “wedding” running gear and crossed the finish line holding hands.
If I’m not running, I enjoy sitting on my back patio with my husband and our two dogs, Charlie and Henri.
Most prized possession:
A pearl necklace that my grandmother gave me before she died. She received it from her brother, who was a jet fighter pilot in World War II. He traveled to Japan during the war and bought a pearl necklace while there for each of his sisters.
All-time top favorite books:
The Alchemist by Paulo Coelho, A Portrait of the Artist as a Young Man by James Joyce, Atlas Shrugged by Ayn Rand, My Name is Asher Lev by Chaim Potok, Pale Fire by Vladimir Nabokov, Rant by Chuck Palahniuk, The Passage by Justin Chronin, Await Your Reply by Dan Chaon, The Forever War by Joe Haldeman, House of Leaves by Mark Z. Danielewski.