Patricia J. Sweeney

Recent Administrative Matters

• Representing a Global 50 company in a Post-Appeals Mediation in a matter involving complex partnership and corporate tax issues. The proposed loss disallowance exceeded $1 billion.
• Representing a foreign-based multinational in a Post-Appeals Mediation in a foreign tax credit matter involving hundreds of millions of dollars in credits.
• Representing a multinational technology company before IRS Appeals regarding the deductibility of a contested liability payment. The proposed disallowance exceeded $500 million.
• Assisting a foreign-based multinational with an IRS Audit by developing audit strategies and advising the client team interfacing with the IRS agents regarding multiple audit issues, including transfer pricing, foreign tax credit, domestic production deduction, R&D credit and tax accounting issues.

Docketed Cases

• Lockheed Martin Corp. v. United States, D. Md. Dkt. 8:12-cv-3725-DKC. Represent the taxpayer in litigation involving R&E credit claimed for aerospace prototypes and the interaction between section 199 and the extraterritorial income exclusion.
• Rehrig v. Commissioner, Nos. 10067-10 and 10070-10 (Tax Ct. filed May 3, 2010) Represent taxpayer in litigation involving application of the S Corp rules. 
• Hercules, Inc. v. Commissioner, No. 21793-03 (Tax Ct. filed Dec. 23, 2003) Represent taxpayer on multiple issues, including contingent liability management company, partnership and claim of right issues. 
• Exxon Mobil Corp. v. United States, 244 F.3d 1341, 2001 U.S. App. LEXIS 5452 (Fed. Cir. 2001), aff’g in part and rev’g in part, 45 Fed. Cl. 581 (1999) Represent taxpayer in matter involving percentage depletion issues. 
• Weyerhaeuser Co. v. United States, 92 F.3d 1148 (Fed. Cir. 1996), rev’g, 32 Fed. Cl. 80 (1994), cert. denied, 519 U.S. 1091 (1997) Represent taxpayer in litigation involving casualty loss deductions arising from the eruption of Mt. St. Helens.