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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 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
  • 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
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