James P. Holden

Of Counsel

• jholden@steptoe.com
• vCard
• Washington Office

James P. Holden is of counsel with the Washington-based law firm of Steptoe & Johnson LLP, where he is a member of the Business Solutions Department.  He formerly served as chair of the firm and as head of its tax practice.

Tax Controversy Practice
Mr. Holden's experience in handling tax litigation and in resolving controversies with the Internal Revenue Service (IRS) at the administrative level spans 40 years of tax practice.  He has been lead counsel in landmark cases that have altered IRS enforcement policies, litigating against attorneys from the US Department of Justice Tax Division and from the IRS Office of Chief Counsel.  Mr. Holden also has extensive experience in handling tax matters before the IRS in the administrative process, including the examination level and before the IRS Appeals Office.  He is particularly well-experienced in the management of large controversy issues before the National Office of the IRS through the technical advice process.  The matters in which Mr. Holden has been involved relate to virtually every substantive aspect of federal tax law.

Tax Policy Practice
A significant part of Mr. Holden's practice involves the resolution of tax policy issues before the Congress, the Treasury Department, and the IRS.  These tax policy issues arise in the context of pending or proposed legislation, proposed Treasury Department regulations, and IRS rulings and procedures.  The objective is to present the legitimate tax policy concerns of our clients and to seek to have those concerns accommodated in the policy resolution process.

Standards of Tax Practice
As co-author of the two leading texts in the area of standards of practice in the tax area, Mr. Holden is recognized as an authority in this unique field.  He is consulted by professional organizations seeking resolution of practice issues, he serves frequently as an expert witness in this area, and he is a well-recognized speaker and lecturer in the area. 

Noteworthy

• Chair, Internal Revenue Service, Commissioner's Advisory Group, 1992-1993
• Regent, American College of Tax Counsel, 1992-1998
• Trustee, American Tax Policy, Institute, President, 1992-1995
• Chair, Internal Revenue Service, Panel on Integrity Issues, 1990-1991
• Adjunct Professor of Tax Law, Georgetown University, 1972-1992
• Co-Author, Standards of Tax Practice, Tax Analysts, 3d Ed. 1999
• Co-Author, Ethical Problems in Federal Tax Practice, Little Brown, 3d Ed. 1995

Professional Affiliations

• American Bar Association, Chair, Tax Section, 1989-1990
• Member, House of Delegates, 1993-present
• American Law Institute, Member, Tax Advisory Group