- J.D.Harvard Law School2002
- M.A. (Philosophy)University of Wisconsin-Milwaukee1999
- B.A. (Philosophy)University of Toledomagna cum laude1997
Steve Dixon is a Member in the Tax Department, where he has been litigating federal tax cases for corporate and individual taxpayers for over 17 years. Mr. Dixon has represented Fortune 500 taxpayers in high-profile trials before the Tax Court (including a multi-billion-dollar transfer-pricing case in that venue), the Court of Federal Claims, and in federal district court. He has been recognized as a Tax Controversy Leader by International Tax Review as well as in Legal 500 United States for tax controversy.
The subject areas of Mr. Dixon's tax cases have been diverse and have included transfer pricing as well as intangible-asset valuation, statutory interpretation, 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.
Successful tax litigation requires persuasive briefing and skilled trial presentation. Mr. Dixon is dedicated to the craft of persuasive writing, having written scores of motions and trial and appellate briefs. Mr. Dixon writes prodigiously, not just in controversies but also publishing on myriad tax subjects including transfer-pricing regulations, interest netting, partnerships, deference, and the rules governing tax practice. He has authored articles in the Journal of Taxation and Business Entities, among other publications, and contributes to the firm's Tax Appellate Blog.
Mr. Dixon has extensive experience with trial presentation—whether it is opening statement, direct examination, or cross-examinations of expert witnesses. Mr. Dixon is experienced speaking on complex topics, having cut his teeth teaching undergraduate philosophy courses while in graduate and law school. With his colleague Loren Ponds, Mr. Dixon co-hosts the tax break podcast, where they tackle current and interesting issues in the tax law. Mr. Dixon regularly presents on tax controversy and litigation topics in a variety of forums, including before various chapters of the Tax Executives Institute. He regularly comments on tax litigation in Tax Notes, Bloomberg, Law360, and other tax publications.
In addition to litigating cases, Mr. Dixon represents taxpayers in controversies before IRS Appeals and at Exam. He has extensive experience writing protests at IRS Appeals. Mr. Dixon also advises clients on other strategic tax issues, excise taxes, privilege and work-product issues, and litigation strategy.
- 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: U.S. Taxes: Contentious, 2017 - 2020
- International Tax Review: Tax Controversy Leaders (U.S.), 2015, 2017
- DC Bar Capital Pro Bono Honor Roll, 2013, 2019
- Member, J. Edgar Murdock Inn of Court (for the U.S. Tax Court)
- Member, American Bar Association Section of Taxation
District of Columbia
Jorge Castro, Tom Cryan, Steven Dixon, Elizabeth Drake, Anthony Provenzano, and Lisandra Ortiz will present to the Tax Executives Institute's (TEI's) Denver Chapter on April 21, 2021.
Loren and Steve will discuss the tax proposals included in the American Jobs Plan, which are meant to fund large infrastructure investments the Biden administration plans to make.
Steven Dixon, Maria O'Toole Jones, and Lisandra Ortiz will present "Ethical Considerations in Tax Practice," to the Tax Executives Institute's (TEI's) New England Chapter on April 9, 2021.
Steve Dixon commented on pending litigation by FedEx Corporation and Liberty Global challenging Treasury Regulations implementing the Tax Cuts and Jobs Act (TCJA).
In this episode, Loren and Steve speak with Mike Cragg from The Brattle Group about economics and transfer pricing valuations.
Steve Dixon commented on the Treasury Department's first effort to justify circumventing the notice-and-comment requirements under the Administrative Procedure Act (APA) for Temporary Regulations i
Under immense pressure to devise a fair and administrable solution for taxing digital businesses by 2020, the OECD yesterday released a public consultation document to test the waters with a potent
Yesterday, Treasury and the IRS issued a joint policy statement
Last week's Ninth Circuit decision in