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 at IRS Appeals and at Exam. Mr. Dixon’s tax work has involved a broad range of issues, including tax accounting, basis and valuation, abandonment losses, transfer pricing, interest netting, statutes of limitations, 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.

• U.S. v. GE HFS Holdings, Inc. Represent 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 district court issued a published opinion (108 AFTR 2d. 2011-7167 (M.D. FL 2011)) that 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. The Ninth Circuit remanded the case to district court to determine the taxpayer's purchase price and allocate the price among the rights. Trial on those issues was held in December 2012.
   
• 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.