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Sam Lapin is Counsel in the Tax Department. He focuses largely on tax controversy and litigation matters.

Sam has experience working with clients during Internal Revenue Service (IRS) audits and before the IRS Independent Office of Appeals on a variety of issues, including the R&D credit, partnership basis adjustments, management fee waivers, charitable contributions, and collection and penalty issues. He has also represented clients in tax litigation matters before the U.S. Tax Court and the U.S. Court of Appeals for the 8th Circuit.

In addition, Sam has experience assisting clients with international tax planning and tax policy matters. 

Sam is also active in the ABA Tax Section, for which he has served as a panelist and contributed to comment projects, and the DC Bar Tax Community. Before joining the firm, Sam was a Law Clerk to Judge Cary Douglas Pugh on the U.S. Tax Court. During law school, he served as Note & Comment Editor for the Temple Law Review.

Representative Engagements
  • Elizabeth Redleaf v. Commissioner, 43 F.4th 825 (8th Cir. 2022) (whether payments received in divorce settlement are division of marital property or alimony) 
  • Successfully negotiated a favorable settlement on behalf of a multinational technology company in an R&D credit matter before IRS Appeals.
  • Negotiated settlements with the IRS after docketing a series of cases in the Tax Court involving the donation of conservation easements.
Rankings and Recognition
  • John S. Nolan Fellow, American Bar Association Section of Taxation, 2023 - 2024
  • The Best Lawyers in America®: Litigation and Controversy - Tax (Ones to Watch), 2023 - 2024
  • The Best Lawyers in America®: Tax Law (Ones to Watch), 2024
  • DC Bar Capital Pro Bono Honor Roll, 2020
Affiliations
  • Member, American Bar Association Tax Section
Admissions
State Admissions
  • District of Columbia
  • Pennsylvania
Court Admissions
  • United States Tax Court
  • United States Court of Appeals for the Eighth Circuit
  • United States Court of Appeals for the Tenth Circuit
Clerkships
  • Law Clerk, Judge Cary Douglas Pugh, U.S. Tax Court
News and Events
Publications
Internal Publication

Monthly Tax Roundup (Volume 3, Issue 4)

Internal Publication

Monthly Tax Roundup (Volume 3, Issue 3)

Internal Publication

Monthly Tax Roundup (Volume 3, Issue 2)

Internal Publication

Monthly Tax Roundup (Volume 3, Issue 1)

Internal Publication

Monthly Tax Roundup (Volume 2, Issue 11)