The History of the Firm

After obtaining his Bachelor’s degree at Stanford University, firm founder Ralph Gano Miller decided that it would be good to combine business (with an emphasis on accounting) with law. With that in mind, he obtained a Master’s degree at the Stanford Business School and then returned to his home town of San Diego and became a member of the first Law School class of the University of San Diego. He began the practice of tax-related law in 1958.

The first associate attorney joined him in 1959 and a partnership was formed in 1960. The firm has continued to grow since that time with tax-related business, tax minimization and estate planning as the major areas of focus.

Over the years, Ralph has always been a leader in the estate planning field, developing estate planning techniques that are widely used by professionals across the country today. With his dedication to obtaining the best possible result for his clients, and his creativity and grasp of estate planning issues, he has always kept the firm on the cutting edge of estate planning practice. He became widely known from his writing and speaking endeavors, and he received one of the first issued certificates of Specialization in Taxation Law. He also developed the first estate planning software program approved by the American Bar Association.

As the firm grew, other practice areas were developed to meet the needs of our clients. To complement the estate planning focus of the firm, Mary Peshel specializes in probate and trust administration and has become recognized as one of San Diego’s most expert practitioners in those areas. As the head of the firm’s Trust and Estate Administration department, Mary has the invaluable experience of both creating the estate plan and carrying it out.

Thomas Monson has headed up the firm’s litigation department for many years and developed a very well recognized position in the area of pension plan litigation and assisting clients whose disability insurance claims have been denied. Because of his expertise, he receives requests for assistance from across the nation. His litigation skills are also evident in the area of probate and trust litigation. Tom was one of the first attorneys in the nation to direct video recordings of the execution of estate planning documents where there might be a possibility of a contest of the client’s competency and/or a claim of undue influence. He was also one of the first attorneys to have a judge admit such video taped evidence in probate or trust trials.

One of Ralph’s many responsibilities as the senior partner and head of the firm is finding outstanding people to contribute to the firm’s success. Ralph became acquainted with Timothy Polacek in pioneering in the area of Employee Stock Ownership Plans, which plans require continuing appraisals of the value of the company. Tim had a university degree in Economics and worked in an appraisal company which did such appraisals. Ralph was very impressed with his abilities and persuaded him to come to work with the firm, where he did a full time job and obtained his law degree at night at the University of San Diego School of Law.

Having worked in the appraisal area and working in the Family Limited Partnership area with Ralph, Tim soon took over the responsibility for the firm’s practice in the Family Partnerships as well as developing a broad reputation for work in the more sophisticated areas of estate planning, including planning for persons with successful businesses or significant portfolios. In recent years Tim has become recognized as the person in San Diego with the most experience in dealing with the Internal Revenue Service in relation to Family Partnerships, currently working on significantly more such IRS audits than anyone else in San Diego. This is due in part to the firm having helped clients create more such partnerships than any other San Diego firm and also to receiving many referrals from both attorneys and accountants for assistance with such matters.

During his time with the firm, William Hoshaw obtained a Masters Degree in Taxation from the University of San Diego School of Law and later became a Certified Specialist in Taxation Law under the California Specialization Program. The other partners proudly tell others that Bill is not only one of the most brilliant people with whom they have worked but that his encyclopedic knowledge of the Internal Revenue Code puts the firm at a distinct advantage in dealing with the toughest taxation matters. Because of Bill’s proficiency in taxation matters, many business clients engage him to provide their more complicated contracts since taxation now pervades most business matters. Bill has also developed a deserved reputation in the unique area of tax-free exchanges of real property, an important area for many San Diegans.

Roberta Repasy came to the firm after over seven years of doing litigation work for the Internal Revenue Service, where she never lost a recorded case. Because the firm in recent years has been providing estate plans for larger estates and has been working in more sophisticated areas, Roberta’s expertise in dealing with tax litigation matters provides a significant advantage. In addition to her tax controversy work, Roberta has worked with Ralph and Tim in the more complicated planning areas, including charitable planning, family limited partnerships and more recently the unique area of Small Insurance Companies. With this necessary experience she studied for and passed the examination and joined Ralph and Bill as a Certified Specialist in Taxation Law.

Another significant area of the firm’s expertise is in the area of retirement planning, including profit sharing plans, pension plans and Employee Stock Ownership Plans (ESOPs) and, more recently, the special 401(k) ESOPs, usually referred to as K-SOPs. The ESOP area has been an very important area of work for the firm for over 25 years, providing a means for developing funds for business clients to create a market for their companies and for sharing the business with employees, and since a change in tax law in 1996, has offered unique opportunities for clients with businesses which have developed significant profits to defer the taxation of large amounts for many years. Despite ongoing changes in the law, Philip Fredricksen continues to offer what we believe to be an effective strategy for clients who are willing to plan aggressively to defer large amounts of taxable income.

In addition to the specialized areas discussed above , our partners and associates are experienced in real property, business and certain litigation matters as well as estate planning.

From the firm’s small beginning, Ralph has built a staff of attorneys whose truly unique abilities and backgrounds have allowed the firm to become the largest in San Diego specializing in the areas of tax minimization , estate planning and business planning, with both the training and the experience necessary to render the best possible service to its clients.