Overview
Steve Dixon has been litigating federal tax cases for corporate and individual taxpayers for almost 20 years. He has represented Fortune 500 taxpayers in high-profile trials before the Tax Court, the Court of Federal Claims, and in federal district court. Steve’s practice often involves complex transfer-pricing controversies; he represented one taxpayer in a multi-billion-dollar transfer-pricing case in the Tax Court. But his controversy practice is diverse and has included disputes about intangible-asset valuation, statutory interpretation, tax accounting, excise taxes, statutes of limitation, debt-equity determinations, and loss deductions. He has represented taxpayers in the consumer products, technology, retail, energy, defense, real estate development, health care, transportation, and banking industries.
Steve has been recognized as a Tax Controversy Leader by International Tax Review as well as in Legal 500 United States for tax controversy. Steve has authored scores of motions and briefs and is an experienced courtroom litigator with experience in everything from opening statement and direct examination to the cross-examination of expert witnesses. Steve also 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, and Law360. 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
Representative Matters
- 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).
Speaking Engagements
-
"Legal Issues with the IRS's Implicit Support GLAM," International Tax Institute Meeting, April 17, 2024
- "Current TP Challenges with Financial Transactions," TP Minds Americas 2023, March 29, 2023
News & Publications
Publications
IRS Transfer Pricing Memo on Implicit Support Has Legal Flaws
Bloomberg Law
March 5, 2024
Media Mentions
E&E News Quotes Steve Dixon and Hunter Johnston Regarding Legal Challenge to Biden Tax Rules
February 29, 2024
Publications
Proposed Hydrogen Tax Credit Regs May Be Legally Flawed
Law360
February 28, 2024
By: N. Hunter Johnston, Steven R. Dixon, Michelle Castaline, Nick Sutter
Media Mentions
February 13, 2024
Media Mentions
Law360 and Bloomberg Law Quote Steve Dixon in Articles About IRS Generic Legal Advice Memorandum
February 7, 2024
Client Alerts
Contentious Proposed Regulations on Hydrogen Tax Credit May Be Vulnerable to Legal Challenges
January 22, 2024
By: N. Hunter Johnston, Steven R. Dixon, Lisa M. Zarlenga, William M. Keyser, Nick Sutter, Michelle Castaline
Focus on Tax Controversy Newsletter
Liberty Global Cases Raise Novel Questions for Appeal
January 10, 2024
Client Alerts
Transfer Pricing GLAM on Implicit Support Raises Many Questions, Offers Few Answers
January 9, 2024
Media Mentions
Bloomberg Tax Quotes Steve Dixon on the Second Appeal to the Eighth Circuit in Medtronic
December 29, 2023
Noteworthy
- 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
Professional Affiliations
- 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