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Alan I. Horowitz

Alan Horowitz’s practice focuses on appellate litigation, with particular experience in federal tax appeals.  Although he practices primarily in the United States Supreme Court and federal courts of appeals, he also represents clients in litigation of legal issues in trial court. More >

Representative Engagements|View All

  • Washington Mutual Inc. v. United States, No. 09-36109 (9th Cir. Mar. 3, 2011) (successfully appealed decision denying basis to intangible assets received in a supervisory merger).
     
  • COSVI v. FAC, No. 08-1576 (1st Cir. Apr. 9, 2009) (Successfully appealed a sanctions award imposed under the district court’s inherent power).
     
  • Robinson v. United States, 335 F.3d 1365 (Fed. Cir. 2003) (executive compensation deduction), cert. denied, 540 U.S. 1105 (2004) (Representation of the controlling shareholder of a film company in persuading the Federal Circuit to reverse an unfavorable decision on an executive compensation issue and then successfully opposing the government's petition for certiorari).
     
  • Arkansas Best Corp. v. Commissioner, 485 U.S. 212 (1988) (Validity of Corn Products doctrine -- whether stock acquired for business purpose can be treated as capital asset).
     
  • United States v. General Dynamics Corp., 481 U.S. 239 (1987) ("All events test" as applied to estimation of future employee health benefit claims against self-insurer).
Government Experience
  • Assistant to the Solicitor General, U.S. Department of Justice, 1979 - 1986
  • Tax Assistant to the Solicitor General, U.S. Department of Justice, 1986 - 1990
Corporate Experience
Rankings and Recognition
  • Chambers USA:  Tax Controversy (National), 2007 - 2014
  • Legal 500:  Tax:  Tax Controversy, 2008, 2010 - 2011
  • The Best Lawyers in America®:  Litigation & Controversy - Tax, 2013 - 2015
Professional and Community Involvement
Bar Admissions
  • District of Columbia
Court Admissions
  • United States Supreme Court
  • United States Court of Appeals for the Federal Circuit
  • United States Court of Appeals for the District of Columbia Circuit
  • United States Tax Court
  • United States Court of Appeals for the First Circuit
  • United States Court of Appeals for the Second Circuit
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Fourth Circuit
  • United States Court of Appeals for the Fifth Circuit
  • United States Court of Appeals for the Sixth Circuit
  • United States Court of Appeals for the Seventh Circuit
  • United States Court of Appeals for the Ninth Circuit
  • United States Court of Appeals for the Tenth Circuit
  • United States Court of Federal Claims
Clerkships
Foreign Languages
  • Hebrew
Education
  • J.D., Columbia University School of Law, 1977
  • S.B., Massachusetts Institute of Technology, 1974