Education
  • J.D.
    Harvard Law School
    2002
  • M.A. (Philosophy)
    University of Wisconsin-Milwaukee
    1999
  • B.A. (Philosophy)
    University of Toledo
    magna cum laude
    1997

Steve Dixon is a Member in the Tax Department, where he focuses on litigating federal tax cases for corporate taxpayers.

Mr. Dixon has represented corporate taxpayers in trials before the Tax Court, the Court of Federal Claims, and in federal district court. He has experience in the circuit courts, authoring several appellate briefs and contributing to others. Mr. Dixon’s practice also involves representing taxpayers in controversies before IRS Appeals and at Exam.

The subject areas of Mr. Dixon’s tax litigation and controversy practice have been diverse and have included, among other things, intangible-asset valuation, transfer pricing, interest netting, tax accounting, excise taxes, statutes of limitation, debt-equity determinations, and loss deductions. He has represented taxpayers in the energy, technology, defense, real estate development, healthcare, transportation, and banking industries.

Mr. Dixon has extensive trial court experience – he has argued motions, performed direct and cross examination of both fact and expert witnesses, and delivered an opening statement. He has drafted petitions, complaints, answers, motions for summary judgment, motions in limine, and pre- and post-trial briefs. His litigation experience extends to all aspects of discovery, including taking and defending the depositions of expert witnesses. Mr. Dixon also advises clients on privilege and work-product issues, as well as litigation strategy.

Mr. Dixon comments on tax litigation in Tax Notes, BNA, and other tax publications. He regularly presents on tax controversy and litigation topics in a variety of forums, including before various chapters of the Tax Executives Institute and at the NYU Institute of Federal Taxation. He has authored articles in the Journal of Taxation and Business Entities, among other publications, and contributes to the firm’s Tax Appellate Blog.

  • The Coca-Cola Company v. Comm’r, Tax Court Dkt. 31183-15. Represent taxpayer in transfer-pricing dispute; trial completed in May 2018.
  • Hewlett-Packard Co. v. Comm'r, 875 F.3d 494 (9th Cir. 2017). Represent taxpayer in an appeal involving a debt-equity recharacterization of a financing transaction involving foreign tax credits and the disallowance of capital losses associated with the transaction.
  • Washington Mutual, Inc. et al. v. United States, 130 Fed. Cl. 653 (2017); aff’d No. 2017-1944, 2018 BL 195976 (Fed. Cir. June 04, 2018). Represent taxpayer in refund suit involving recovery of basis in intangible assets acquired in supervisory mergers during the 1980s.
  • Lockheed Martin Corp. v. United States, D. Md. Dkt. 8:12-cv-3725-DKC. Represented taxpayer in litigation involving R&E credit claimed for aerospace prototypes and the interaction between section 199 and the extraterritorial income exclusion.
  • Howard Hughes Properties Inc. et al. v. Commissioner, 142 T.C. 355 (2014); aff’d 805 F.3d 175 (5th Cir. 2015). Represented taxpayer in litigation about whether a residential real estate developer is permitted to use completed contract method of accounting.
  • U.S. v. GE HFS Holdings, Inc. 108 AFTR 2d 2011-7167 (D Fl 2011). Represented a subsidiary of GE Capital in litigation the government brought under Code section 3505(b) against that subsidiary for conduct by a predecessor.
  • Washington Mutual, Inc. v. United States, 636 F.3d 1207 (9th Cir. 2011). Represented a financial institution in a refund suit involving whether a taxpayer that participates in a supervisory merger of a failing savings and loan institution is entitled to basis for its acquisition of the right to operate interstate savings and loan branches following the merger.
  • ExxonMobil Corp. v. Commissioner, No. 18618-89 (Tax Ct. filed July 26, 1989) No. 18432-90 (Tax Ct. filed Aug. 16, 1990). Represented a large multi-national company in dispute over whether interest netting is available for overlapping period in 1980s and whether Tax Court has jurisdiction to hear interest-netting claim. 
  • Legal 500: Tax: Contentious, 2017 - 2018
  • International Tax Review: Tax Controversy Leaders (U.S.), 2015, 2017
  • Member, J. Edgar Murdock Inn of Court (for the U.S. Tax Court) 
  • Member, American Bar Association Section of Taxation
Bar Admissions
  • District of Columbia
Court Admissions
  • United States Tax Court
  • United States Court of Federal Claims
  • United States Court of Appeals for the District of Columbia Circuit
  • United States District Court for the District of Maryland
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Ninth Circuit
11.02.2017
Speaking Engagement

Steven R. Dixon, Maria O'Toole Jones, and Michael M. Lloyd* will be speaking during the 42nd Annual Insurance Tax Conference (ITC) in Orlando, FL.

Orlando, FL

12.22.2011

On December 16, 2011, the IRS and the Treasury Department issued comprehensive final transfer pricing regulations related to cost sharing arrangements for the development of intangibles ("CSAs").

Tax Alert