| Steve Dixon practices in the area of federal income taxation with a focus on tax controversy and litigation. Mr. Dixon has worked on tax disputes for both corporate and individual clients at the audit level, at IRS Appeals, and in litigation. Mr. Dixon’s tax work has involved a broad range of issues, including basis and valuation, abandonment losses, international tax, assignment of income, the validity of Treasury Regulations, and the deductibility of settlement payments. He has also worked on state tax controversies and on several appellate briefs.
Mr. Dixon has spoken at TEI and at the NYU Institute of Federal Taxation. He has co-authored articles in the Journal of Taxation and other publications. More > Steve Dixon practices in the area of federal income taxation with a focus on tax controversy and litigation. Mr. Dixon has worked on tax disputes for both corporate and individual clients at the audit level, at IRS Appeals, and in litigation. Mr. Dixon’s tax work has involved a broad range of issues, including basis and valuation, abandonment losses, international tax, assignment of income, the validity of Treasury Regulations, and the deductibility of settlement payments. He has also worked on state tax controversies and on several appellate briefs.
Mr. Dixon has spoken at TEI and at the NYU Institute of Federal Taxation. He has co-authored articles in the Journal of Taxation and other publications.
Mr. Dixon has also worked at Baker & McKenzie in Chicago and Shearman & Sterling in Washington, D.C. < Brief Bio
- Washington Mutual, Inc. v. United States, 636 F.3d 1207 (9th Cir. 2011). Represent a financial institution in a refund suit involving whether a taxpayer that participates in a supervisory merger of a failing savings and loan institution is entitled to basis for its acquisition of the right to operate interstate savings and loan branches following the merger. Ninth Circuit unanimously held for Washington Mutual and found that taxpayer had tax basis in rights. Ninth Circuit remanded to district court to determine amount of basis.
- ExxonMobil Corp. v. Commissioner, No. 18618-89 (Tax Ct. filed July 26, 1989) No. 18432-90 (Tax Ct. filed Aug. 16, 1990). Represented a large multi-national company in dispute over whether interest netting is available for overlapping period in 1980s and whether Tax Court has jurisdiction to hear interest-netting claim. Tax Court held in ExxonMobil's favor, finding that the Tax Court has jurisdiction to hear the claim and that interest-netting is available.
Professional and Community Involvement
- Member, J. Edgar Murdock Inn of Court (for the U.S. Tax Court)
- Member, American Bar Association Section of Taxation
Court Admissions - United States Tax Court
- United States Court of Federal Claims
- 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
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
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