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Steven R. Dixon

Steve Dixon is a Member in the Tax Department, where he focuses on litigating federal tax cases for corporate taxpayers.

Mr. Dixon has represented corporate taxpayers in trials before the Tax Court, the Court of Federal Claims, and in federal district court. He has experience in the circuit courts, authoring several appellate briefs and contributing to others. Mr. Dixon’s practice also involves representing taxpayers in controversies before IRS Appeals and at Exam.

The subject areas of Mr. Dixon’s tax litigation and controversy practice have been diverse and have included, among other things, intangible-asset valuation, transfer pricing, interest netting, tax accounting, excise taxes, statutes of limitation, debt-equity determinations, and loss deductions. He has represented taxpayers in the energy, technology, defense, real estate development, healthcare, transportation, and banking industries.

Mr. Dixon has extensive trial court experience -- he has argued motions, performed direct and cross examination of both fact and expert witnesses, and delivered an opening statement. He has drafted all manners of pleadings and briefs, including petitions, complaints, answers, motions for summary judgment, motions in limine, and pre- and post-trial briefs. His litigation experience extends to all aspects of discovery, including taking and defending the depositions of expert witnesses. Mr. Dixon also advises clients on privilege and work-product issues, as well as litigation strategy. More >

Representative Engagements|View All

  • Hewlett-Packard Co. v. Comm'r, Nos. 14-73047, 14-73048. Represent taxpayer in the appeal of an adverse U.S. Tax Court decision to the U.S. Court of Appeals for the Ninth Circuit. The appeal involves a debt-equity recharacterization of a financing transaction involving foreign tax credits and the disallowance of capital losses associated with the transaction.
     
  • Lockheed Martin Corp. v. United States, D. Md. Dkt. 8:12-cv-3725-DKC. Represent taxpayer in litigation involving R&E credit claimed for aerospace prototypes and the interaction between section 199 and the extraterritorial income exclusion. 
     
  • Washington Mutual, Inc. et al. v. United States, U.S. Court of Federal Claims Case Nos. 08-211T and 08-321T. Represent taxpayer in refund suit involving recovery of basis in intangible assets acquired in supervisory mergers during the 1980s. The cases are in set for trial in February 2016. 
     
  • Howard Hughes Properties Inc. et al. v. Commissioner, Tax Court Dkt. 10565-11. Represented taxpayer in litigation about whether a residential real estate developer is permitted to use completed contract method of accounting. 
     
  • U.S. v. GE HFS Holdings, Inc. 108 AFTR 2d 2011-7167 (D Fl 2011). Represented a subsidiary of GE Capital in litigation the government brought under Code section 3505(b) against that subsidiary for conduct by a predecessor. Miller & Chevalier prevailed on a motion for partial summary judgment regarding a statute-of-limitations issue. The court’s opinion adopted the primary arguments from Miller & Chevalier’s summary judgment motion.
Government Experience
Corporate Experience
Rankings and Recognition
  • International Tax Review: Tax Controversy Leaders (U.S.), 2015
Professional and Community Involvement
  • Member, J. Edgar Murdock Inn of Court (for the U.S. Tax Court) 
  • Member, American Bar Association Section of Taxation
Bar Admissions
  • District of Columbia
Court Admissions
  • United States Tax Court
  • United States Court of Federal Claims
  • United States District Court for the District of Maryland
  • United States Court of Appeals for the District of Columbia Circuit
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Ninth Circuit
Clerkships
Foreign Languages
Education
  • J.D., Harvard Law School, 2002
  • M.A. (Philosophy), University of Wisconsin-Milwaukee, 1999
  • B.A. (Philosophy), University of Toledo, magna cum laude, 1997