Steve Dixon has been litigating federal tax cases for corporate and individual taxpayers for over 17 years. He 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. Steve 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 Steve'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, health care, transportation, and banking industries.
Steve has extensive experience with trial presentation, handling everything from opening statement and direct examination to the cross-examination of expert witnesses. And Steve has written prolifically in tax litigation, authoring scores of motions and briefs. In addition to litigating cases, Steve represents taxpayers in controversies before IRS Appeals and at Exam. He advises clients on other strategic tax issues, excise taxes, privilege and work product issues, and litigation strategy.
Steve publishes on myriad tax subjects, including on 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 regularly comments on tax litigation in Tax Notes, Bloomberg, Law360, and other tax publications. And Steve regularly presents on tax controversy and litigation topics in a variety of forums, including before various chapters of the Tax Executives Institute.
- District of Columbia
- US Tax Court
- US District Court, District of Maryland
- US Court of Federal Claims
- US Court of Appeals, Third Circuit
- US Court of Appeals, Ninth Circuit
- US Court of Appeals, District of Columbia Circuit
- J.D., Harvard Law School, 2002
- M.A., University of Wisconsin-Milwaukee, 1999
- B.A., University of Toledo, 1997, magna cum laude
- The Coca-Cola Company v. Commissioner, Tax Court Dkt. 31183-15 (tried in 2018; decision issued Nov. 18, 2020).
- 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).
- Hewlett-Packard Co. v. Commissioner, 875 F.3d 494 (9th Cir. 2017).
- Howard Hughes Properties Inc. et al. v. Commissioner, 142 T.C. 355 (2014); aff’d 805 F.3d 175 (5th Cir. 2015).
- Lockheed Martin Corp. v. United States, Md. Dkt. 8:12-cv-3725-DKC.
- United States v. GE HFS Holdings, Inc., 108 AFTR 2d 2011-7167 (D Fl 2011).
- Washington Mutual, Inc. v. United States, 636 F.3d 1207 (9th Cir. 2011); 996 F. Supp. 2d 1095 (W.D. Wash. 2014); aff'd 856 F.3d 711 (9th Cir. 2017).
News & Publications
January 10, 2022
October 6, 2021
- Legal 500, US Taxes: Contentious, 2017-2022
- International Tax Review: Tax Controversy Leaders (US), 2015, 2017
- DC Bar Capital Pro Bono Honor Roll, 2013, 2019
- Member, J. Edgar Murdock Inn of Court (for the US Tax Court)
- Member, American Bar Association Section of Taxation
- Fellow, American College of Tax Counsel