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Patricia J. Sweeney

Patricia Sweeney has practiced exclusively in the area of federal taxation for more than 35 years, advising large U.S. and foreign-based multinationals regarding the resolution of federal tax disputes. She has extensive experience evaluating tax positions, developing strategic responses to Internal Revenue Service (IRS) challenges and resolving federal income tax controversies before the IRS and in court.

Ms. Sweeney's broad range of clients in the automotive, oil and gas, natural resources, chemical, financial, aerospace, utility and telecommunications industries hire her to resolve their most pressing tax controversy problems. The substantive areas in which she successfully represents clients include: tax accounting issues (including depreciation, casualty loss, capitalization, inventory and accrual issues); research and development (R&D) credits, partnership taxation, domestic production deduction issues, transfer pricing, tax structured transactions, taxation of financial instruments, worker classification and foreign tax credits. More >

Representative Engagements|View All

Recent Administrative Matters

  • Representing a Global 50 company in a Post-Appeals Mediation in a matter involving complex partnership and corporate tax issues. The proposed loss disallowance exceeded $1 billion.
     
  • Representing a foreign-based multinational in a Post-Appeals Mediation in a foreign tax credit matter involving hundreds of millions of dollars in credits.
     
  • Representing a multinational technology company before IRS Appeals regarding the deductibility of a contested liability payment. The proposed disallowance exceeded $500 million.
     
  • Assisting a foreign-based multinational with an IRS Audit by developing audit strategies and advising the client team interfacing with the IRS agents regarding multiple audit issues, including transfer pricing, foreign tax credit, domestic production deduction, R&D credit and tax accounting issues.

Docketed Cases

  • Lockheed Martin Corp. v. United States, D. Md. Dkt. 8:12-cv-3725-DKC. Represent the taxpayer in litigation involving R&E credit claimed for aerospace prototypes and the interaction between section 199 and the extraterritorial income exclusion.
     
  • Rehrig v. Commissioner, Nos. 10067-10 and 10070-10 (Tax Ct. filed May 3, 2010) Represent taxpayer in litigation involving application of the S Corp rules.
Government Experience
Corporate Experience
Rankings and Recognition
  • Legal 500: Tax: Non-Contentious, 2013 - 2016
  • Legal 500: Tax: International Tax, 2013 - 2015
  • Legal 500: Tax: Tax Controversy, 2012 - 2015
  • International Tax Review: Women in Tax Leaders, 2015 - 2016
  • International Tax Review: Tax Controversy Leaders (U.S.), 2015
  • Chambers USA: Tax (District of Columbia), 2009 - 2011
Professional and Community Involvement
  • Member, Court Procedure and Practice Committee, Section of Taxation, American Bar Association
Bar Admissions
  • District of Columbia
Court Admissions
  • United States Tax Court
  • United States Court of Federal Claims
  • United States Court of Appeals for the Federal Circuit
  • United States District Court for the District of Maryland
Clerkships
Foreign Languages
Education
  • LL.M. (Taxation), New York University School of Law, 1983
  • J.D., Boston University School of Law, 1980
  • B.A., University of Michigan, Phi Beta Kappa, 1977