Samuel A. Lapin
Counsel
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 active in the American Bar Association (ABA) Tax Section and DC Bar Tax Community. He is a member of the ABA Tax Section Appointments to the Tax Court Committee and has served as a presenting panelist for educational programs and contributor to comment projects. 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
- Advising a U.S. semiconductor manufacturer in commenting on the CHIPS Act regulations with regard to the implementation of the advanced manufacturing investment credit.
- Representing a national financial services provider’s clients in IRS audits on NQDC plans, challenging novel IRS arguments that would reverse long-standing law supporting widely-accepted deferred compensation arrangements.
- 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 resolved complicated and fact-intensive R&E credit issues for a leading technology company.
- 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
- Legal 500: Tax: International Tax, 2024
- The Best Lawyers in America®: Litigation and Controversy - Tax (Ones to Watch), 2023 - 2025
- The Best Lawyers in America®: Tax Law (Ones to Watch), 2024 - 2025
- DC Bar Capital Pro Bono Honor Roll, 2020
Affiliations
- Member, Appointments to the Tax Court Committee, American Bar Association Tax Section
- Board Member, Theodore Tannenwald Jr. Foundation for Excellence in Tax Scholarship, American College of Tax Counsel
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
- United States Court of Federal Claims
Clerkships
- Law Clerk, Judge Cary Douglas Pugh, U.S. Tax Court
News and Events
News
Events
Speaking Engagement
American Bar Association 2025 Midyear Tax Meeting
Speaking Engagement
American Bar Association Virtual 2024 Fall Tax Meeting
Speaking Engagement
National Preservation Law Conference 2024
Speaking Engagement
ABA 2024 May Tax Meeting
Publications
Internal Publication
Deregulatory Update: Notice 2025-19 Triggers a Significant Increase in Input on the Priority Guidance Plan
Internal Publication
The Growing Impact of Loper Bright on the Tax Court
External Publication
Administration Order to Rescind Guidance Raises Questions Under the APA
Internal Publication
District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ
Internal Publication