Tax Audits, Appeals & Litigation Representative Engagements

Although most of our tax controversy work is confidential, the following is a selection of our lawyers' cases of public record:

  • BrokerTec Holdings Inc. v. Commissioner, No. 4099-20 (T.C. filed Mar. 2, 2020) (Section 118)
  • ICAP Global Broking Inc. v. Commissioner, No. 4109-20 (T.C. filed Mar. 2, 2020) (Section 118)
  • Shiloh Indus., Inc. v. Commissioner, No. 020802-18 (T.C. filed Oct. 22, 2018) (research credits).
  • AT&T Advertising, L.P. v. United States, No. 1:16-cv-00272- RTH (Fed. Cl. filed Feb. 26, 2016) (section 199 deduction).
  • BrokerTec Holdings Inc. v. Commissioner, 117 T.C.M. (CCH) 1146,rev’d, No. 19-2603 (3d Cir. July 11, 2019) (treatment of relocation grants as contributions to capital).
  • Corporate Executive Board Company v. Virginia Department of Taxation, 96 Va. Cir. 287 (Va. Cir. Ct. 2017), aff’d, 822 S.E.2d 918 (Va. 2019) (alternative apportionment for sales factor sourcing).
  • Vesta Corporation v. Commissioner, Nos. 26847-16, 26503-17 (T.C. Nov. 13, 2018) (section 199 deduction for software).
  • Trusted Media Brands, Inc. v. United States, 2017-2 U.S.T.C. ¶ 50,359 (S.D.N.Y. 2017), aff’d, 899 F.3d 175 (2d Cir. 2018) (statute of limitations applicable to claim for refund based on change to deduction of foreign taxes paid).
  • El Paso Corp. v. United States, 2014-1 U.S.T.C. ¶ 50, 219 (S.D. Tex. 2012), aff'd, 748 F.3d 225 (5th Cir. 2014) (improper tax assessment under mitigation rules).
  • Union Carbide Corp. v. Commissioner, 97 T.C.M. (CCH) 1207 (2009), aff'd, 697 F.3d 104 (2d Cir. 2012) (research credits).
  • District of Columbia Office of Tax & Revenue v. BAE Systems Enterprise Systems, Inc., 56 A.3d 477 (D.C. 2012) (tax credits and incentives for qualified high technology companies).
  • Marriott Int'l Resorts, L.P. v. United States,83 Fed. Cl. 291 (2008), aff'd, 586 F.3d 962 (Fed. Cir. 2009) (short sale liability excluded from partnership basis).
  • Marriott Int'l Resorts, L.P. v. United States, 437 F.3d 1302 (Fed. Cir. 2006) (and related) (procedures for IRS to invoke deliberative process privilege).
  • Weyerhaeuser Co. v. Commissioner, No. 4712-05 (T.C. Nov. 30, 2005) (qualification of interest on solid waste disposal bonds for tax exemption).
  • E.I. DuPont de Nemours and Co. v. United States, No. 1:01-cv-00449-MCW (Fed. Cl. May 19, 2006) (allocation of purchase price for purchased business to supply contract).
  • Exxon Corp. v. Commissioner, 113 T.C. 338 (1999), acq. in result, 2001-2 C.B. xv (foreign tax credit).
Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, Brussels, and Shanghai.

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