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James R. Gadwood

Jim Gadwood* is Counsel in the Tax Department. His practice focuses on federal civil tax controversies and other taxpayer interactions with the Internal Revenue Service. He has experience representing both corporate and individual taxpayers in matters involving federal, state and local tax authorities. Mr. Gadwood has been described by clients in Legal 500 as a lawyer that combines "knowledge and ability with outstanding customer service and interpersonal, financial, business and commercial skills."

*Admitted in New York. Not admitted in the District of Columbia. Practicing under the supervision of a member of the D.C. Bar.

Representative Engagements|View All

Federal Tax Audits 

  • Obtained a full IRS concession of a cross-border debt-equity issue involving several billion dollars of proposed tax, penalties, and interest. 
  • Prepared a multilateral advance pricing agreement request.

State and Local Tax Audits 

  • Reduced a proposed assessment of New York City General Corporation Tax by millions of dollars in an audit involving formulary apportionment. 
  • Experience with New York City Real Property Transfer Tax audits.


  • Used the docketed Appeals process to obtain a no-change stipulated decision in a Tax Court case involving IRS assertions of underreported income. 
  • Negotiated a multi-year settlement with the IRS after filing a motion for summary judgment in a Tax Court case involving the TEFRA statute of limitation.
Government Experience
Corporate Experience
Rankings and Recognition
  • Legal 500: Tax: Contentious, 2016
Professional and Community Involvement
  • Member, American Bar Association, Section of Taxation, Administrative Practice Committee 
  • Member, New York State Bar Association
Bar Admissions
  • New York
Court Admissions
  • United States Tax Court
Foreign Languages
  • J.D., Boston University School of Law, 2008
  • B.A., University of Michigan, 2005