Sheri A. Dillon focuses her practice on federal tax controversy matters, guiding clients through Internal Revenue Service (IRS) examinations and appeals, the administrative claims process, and litigation. She counsels clients on a range of business and tax-planning matters, with a particular focus on high-net-worth individuals, partnership transactions, and closely held businesses.
Sheri has significant tax litigation experience and has appeared before the U.S. Tax Court, district and appellate courts, and the Court of Federal Claims (COFC). She represents corporate taxpayers, Tax Equity and Fiscal Responsibility Act (TEFRA) and Bipartisan Budget Act partnerships, partners, tax-exempt organizations, and global high-wealth taxpayers across a wide range of industries, including financial services, private equity, hedge fund, real estate, energy, manufacturing, and consumer products.
Sheri's recent work includes matters involving economic substance, substance-over-form, and bona fide partnership issues; the taxation of partnerships and partners; financial products; income tax accounting; cancellation of indebtedness income; employment tax; debt-equity classification; charitable contribution deductions; tax-exempt organizations; tax credits; and valuation. She also represents taxpayers and investors in promoter audit investigations.
Effective August 2026, Sheri will be Chair-Elect of the American Bar Association (ABA) Section of Taxation. She is also Director and President of the Washington, DC Center for Public Interest Tax Law, which provides pro bono tax services for low-income taxpayers.
Prior to joining the firm, Sheri was a partner with a global law firm.
- Appeal pending on ownership of certain derivative contracts or underlying shares and mark-to-market accounting issues
- Obtained an IRS letter of discontinuance in an Internal Revenue Code § 6700/6701 IRS investigation
- Negotiated a favorable settlement for a charitable contribution issue and dismissal of Tax Court case on mootness grounds
- Obtained full IRS concession on a partnership issue followed by a stipulated decision entered by the Tax Court
- Prevailed in the COFC on the proper allocation of items of long-term capital gain
- Prevailed in a district court on issues involving economic substance and corporate-owned life insurance policies
- Obtained full IRS concession on a pro bono matter where the IRS conceded the taxpayer's entitlement to earned income tax credit followed by a stipulated decision entered by the Tax Court
- Chambers High Net Worth Guide: Tax: Private Client (Nationwide), 2025
- Chambers USA: Tax (District of Columbia), 2006 - 2011, 2014 - 2016, 2022 - 2026
- Chambers USA: Tax: Controversy (Nationwide), 2022 - 2026
- ABA Section of Taxation's Janet Spragens Pro Bono Award, 2023
- Legal 500: Tax: U.S. Taxes: Contentious, 2023 - 2026
- The Best Lawyers in America®: Tax Law, 2018 - 2026
- The Best Lawyers in America®: Tax, Litigation and Controversy, 2024 - 2026
- Law360: Tax Practice Group of the Year, 2017
- Director and President, Washington, DC Center for Public Interest Tax Law
- Member, Texas Federal Tax Institute Advisory Board
- Member, Tax Committee, U.S. Court of Federal Claims Advisory Council
- Fellow, American College of Tax Counsel
- Retired Vice Chair for Pro Bono and Outreach, Tax Section, American Bar Association
- Retired Council Director, Tax Section, American Bar Association
- Retired Chair, Administrative Practice Committee, Tax Section, American Bar Association
- Chair-Elect (effective August 2026), Tax Section, American Bar Association
State Admissions
- District of Columbia
- Georgia
Court Admissions
- United States Tax Court
- United States Court of Appeals for the Second Circuit
- United States Court of Appeals for the Sixth Circuit
- United States Court of Appeals for the Federal Circuit
- United States Court of Federal Claims