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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 basis and valuation, tax accounting, abandonment losses, transfer pricing, interest netting, statutes of limitations, debt-equity, and excise taxes. He advises clients on privilege and work-product issues and litigation strategy. He has also worked on state tax controversies and on several appellate briefs.

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

  • 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. The case is in discovery. 
     
  • 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 discovery. 
     
  • Howard Hughes Properties Inc. et al. v. Commissioner, Tax Court Dkt. 10565-11. Represent taxpayer in litigation about whether a residential real estate developer is permitted to use completed contract method of accounting. Trial was held in November 2012. 
     
  • 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. The government’s action was more than ten years after the underlying assessments against the predecessor and therefore out of time under the applicable Treasury Regulation. The government argued that an intervening bankruptcy extended the statute of limitations, relying on a Seventh Circuit decision to that effect. Miller & Chevalier prevailed on a motion for partial summary judgment on the statute-of-limitations issue arguing that the Seventh Circuit decision was no longer on point because of an intervening Supreme Court decision on section 3505(b) and a contrary Ninth Circuit decision, among other things. The court’s opinion adopted the primary arguments from Miller & Chevalier’s summary judgment motion. 
     
  • 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. Miller & Chevalier prevailed at the Ninth Circuit, which reversed an adverse summary judgment decision and found that the taxpayer had tax basis in intangible rights. 
     
  • 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.
Government Experience
Corporate Experience
Rankings and Recognition
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 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