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Steven R. Dixon

Steve Dixon practices in the area of federal income taxation with a focus on tax litigation and controversy. Mr. Dixon has represented clients in trials at the U.S. Tax Court and in federal district court. He has also represented clients in the U.S. Court of Federal Claims and at IRS Appeals and Exam. Mr. Dixon’s tax work has involved a broad range of issues, including intangible-asset valuation, transfer pricing, tax accounting, loss deductions, interest netting, statutes of limitations, debt-equity determinations, and excise taxes. He advises clients on privilege and work-product issues and litigation strategy. He also regularly works on circuit court appeals, authoring several appellate briefs and contributing to others.

Mr. Dixon regularly presents at TEI and has spoken at the NYU Institute of Federal Taxation. He has co-authored articles in the Journal of Taxation and other publications and contributes to the firm's Tax Appellate Blog.

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
Foreign Languages
  • J.D., Harvard Law School, 2002
  • M.A. (Philosophy), University of Wisconsin-Milwaukee, 1999
  • B.A. (Philosophy), University of Toledo, magna cum laude, 1997