Areas of Practice
Education
  • Georgetown University Law Center, LL.M., Taxation, 1984
  • The University of Kansas School of Law, J.D., 1978, William L. Burdick Prize, Senior Articles Editor, Kansas Law Review, Order of the Coif
  • Cornell University, B.A., 1975
Bar & Court Admissions
  • District of Columbia
  • Court of Federal Claims
  • US Tax Court
  • US Supreme Court
  • US Courts of Appeals
  • US District Court

J. Walker Johnson

Partner
1330 Connecticut Avenue, NW
Washington DC 20036
TEL: +1 202 429 6225
FAX: +1 202 429 3902

Walker Johnson focuses his practice on tax controversies and tax litigation, and tax planning.

Mr. Johnson’s tax controversy practice includes audit examinations, technical advice requests, protests, IRS Appeals proceedings, and refund claims.  He has litigated numerous cases in district court, the Tax Court and the Court of Federal Claims, as well as in various Circuit Courts of Appeals and the United States Supreme Court.

On the tax planning side his practice has included company, financial product and investment tax issues, corporate transaction matters, captive insurance, and penalty and interest questions.  This work on behalf of a wide variety of clients has involved giving informal advice, issuing opinion letters and obtaining private letter rulings from the IRS National Office.

Mr. Johnson’s practice has emphasized the taxation of insurance companies and other financial institutions.

Prior to joining Steptoe, Mr. Johnson was a Trial Attorney at the Department of Justice’s Tax Division, from 1978 to 1984.  There his primary responsibility was defending tax refund suits brought against the government by taxpayer/plaintiffs.  During his tenure, he settled hundreds of such cases, and litigated others to published opinions.  Mr. Johnson was awarded the Tax Division’s Outstanding Attorney Award in 1982.

Since 1987, Mr. Johnson has served as an Adjunct Professor of Law in the Graduate Tax Program at the Georgetown University Law Center.  He teaches a course titled Taxation of Financial Institutions and Products, which covers the taxation of life insurance companies, property/casualty insurance companies, banks and thrifts, RICs, REITs, REMICs, captive insurance, and financial products.

Representative Matters

  • John Hancock Life Insurance Company v. Commissioner, Tax Court Docket Nos. 6404-09, 7083-10, and 7084-10
  • Southern California Edison Co. v. United States, Fed. Cl. Docket No. 07-874T
  • United States v. Textron—2007-2 ¶ USTC 50,605, Taxpayer prevails in quashing an administrative summons seeking disclosure of tax accrual workpapers
  • John Hancock Financial Services, Inc. v. United States, 57 Fed. Cl. 643 (2003), aff'd, 378 Fed. Cir. 1302 (2004) 
  • The Bear Stearns Companies v. United States, Fed. Cl. Docket No. 03-2874T
  • Allmerica Financial Corp v. United States, Fed. Cl. Docket No. 03-2746T
  • American Electric Power Co., Inc. v. United States, 136 F. Supp. 2d 762 (S.D. Ohio 2001), aff'd, 326 F.3d 737 (6th Cir. 2003)  
  • Allmerica Financial Corp v. United States, Fed. Cl. Docket No. 00-330T
  • Massachusetts Mutual Life Insurance Co. v. United States, Fed. Cl. Docket No. 00-204T
  • CUNA Mutual Life Insurance Co. v. United States, 39 Fed. Cl. 660 (1997), aff'd, 169 F.3d 737 (Fed. Cir. 1999)
  • New York Life Insurance Co. v. United States, 96-1 U.S.T.C. (CCH)  50,066 (Cl. Ct.), aff'd, 118 F.3d 1553 (Fed. Cir. 1997), cert. denied, 118 S. Ct. 1559 (1998)
  • Indianapolis Mutual Life Insurance Co. v. United States, 940 F. Supp. 1370 (S.D. Ind. 1996), aff'd, 115 F.3d 430 (1997)
  • Allmerica Financial Corp v. United States, Fed. Cl. Docket No. 97-747T
  • Massachusetts Mutual Life Insurance Co. v. United States, Fed. Cl. Docket No. 97-619T
  • Connecticut Mutual Life Insurance Co. v. Commissioner, 106 T.C. 445 (1996)
  • National Life Insurance Co. v. Commissioner, 103 T.C. 615 (1995), aff'd, 103 F.3d 5 (2nd Cir. 1995)
  • American Mutual Life Insurance Co. v. United States, 93-2 U.S.T.C. (CCH)  50,652 (S.D. Iowa 1993), rev'd, 43 F.3d 1172 (8th Cir. 1994), cert. denied, 116 S. Ct. 335 (1995)
  • Massachusetts Mutual Life Insurance Co. v. United States, Fed. Cl. Docket No. 93-578T
  • New York Life Insurance Co. v. United States, Fed. Cl. Docket No. 93-367T
  • Northwestern Mutual Life Insurance Co. v. United States, Fed. Cl. Docket No. 93-323T
  • Phoenix Mutual Life Insurance Co. v. Commissioner, D.C. Conn Docket No. 292CV00134 (AHN)
  • Fleet/Norstar Corp. v. Commissioner, T.C. Docket No. 3303-91
  • Phoenix Mutual Life Insurance Co. v. Commissioner, 96 T.C. 481 (1991)
  • Phoenix Mutual Life Insurance Co. v. Commissioner, 96 T.C. 497 (1991)
  • Union Pacific Corp. v. United States, Cl. Ct. Docket No. 90-3865T
  • Massachusetts Mutual Life Insurance Co. v. United States, Cl. Ct. Docket No. 90-286T
  • Union Pacific Corp. v. United States, Cl. Ct. Docket No. 669-89T
  • Union Pacific Corp. v. United States, Cl. Ct. Docket No. 543-89T
  • Massachusetts Mutual Life Insurance Co. v. United States, Cl. Ct. Docket No. 425-88T
  • Union Pacific Corp. v. Commissioner, 91 T.C. 32 (1988)
  • Missouri Pacific Corp. v. United States, Cl. Ct. Docket No. 504-87T
  • Union Pacific Corp. v. United States, 9 Ct. Cl. 702 (1986), aff'd, 847 F.2d 1567 (1988)
  • United States v. Fink, 483 U.S. 89 (1987)
  • Atlantic Richfield Co. v. Commissioner, T.C. Docket No. 6148-97
  • Hughes Properties, Inc. v. United States, 476 U.S. 593 (1986) (amicus brief) 
  • Union Pacific Corp. v. United States, 11 Cl. Ct. 177 (1986)
  • Union Pacific Corp. v. Commissioner, T.C, Docket No. 300226-82
  • Union Pacific Corp. v. Commissioner, T.C. Docket No. 24152-81
  • Union Pacific Corp. v. Commissioner, T.C. Docket No. 11554-80
  • Ohio National Life Insurance Co. v. United States, 11 Ct. Cl. 477 (1986)
  • Northwestern Mutual Life Insurance Co. v. United States, 7 Cl. Ct. 501 (1984)
  • General Dynamics, Inc. v. United States, 6 Cl. Ct. 250 (1984)   
  • Massachusetts Mutual Life Insurance Co. v. United States, 5 Cl. Ct. 501 (1984) 
  • Viereck v. United States, 3 Cl. Ct. 745 (1983)

Noteworthy

  • Best Lawyers in America, Tax Law, 2013-2015
  • Chambers USA, Tax: Controversy (Nationwide), 2011-2014
  • Legal 500 US, Tax: Controversy, 2013-2014

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