Lindsay L. Clayton
Biography
Lindsay L. Clayton is a partner in the Tax Practice Group of Baker McKenzie’s Washington, DC office.
Prior to joining the Firm, Lindsay served as Assistant Director in the Tax Litigation Branch of the Civil Division at the U.S. Department of Justice, where she oversaw complex civil tax litigation nationwide, including matters involving regulatory challenges under the Administrative Procedure Act, employee retention credits, foreign banking and information reporting penalties, Chapter 11 bankruptcies, IRS summons disputes, jeopardy levies, white collar fraud, tax procedure issues, and listed transactions.
Before that she served as a Tax Division Trial Attorney, handling a varied docket including complex estate and gift tax issues, research credits, the domestic production activities deduction, and the extraterritorial income exclusion regime. During that time she handled both jury and bench trials and engaged in extensive civil discovery and motions practice.
Practice Focus
Representative Legal Matters
Prior to joining Baker McKenzie, Lindsay litigated the following matters:
- Bren Simon v. United States – USD 21 million estate tax dispute involving the valuation of the Indiana Pacers basketball team.
- Lockheed Martin Corporation v. United States – Federal tax refund action seeking more than USD 16 million in research tax credits, involving a novel and contested civil procedure issue.
- Vancouver Clinic, Inc. v. United States – Obtained summary judgment in a case involving the tax treatment of a novel physician compensation arrangement.
- United States v. Talmage; United States v. RiverCliff Farm, Inc.; and Wadsworth v. Talmage – Related proceedings involving more than USD 10 million in unpaid taxes, cross-border financial fraud, foreign discovery, issues of first impression, multiple appeals, and an advisory opinion from the Oregon Supreme Court.
- Richard Blanco v. United States – Federal tax refund action involving contested penalties and a claimed reasonable-cause defense, resulting in a complete victory following a two-day bench trial.
- United States v. George Steven Parker – Multi-day trial concerning whether more than USD 3.8 million in tax liabilities were subject to the fraud exception to bankruptcy discharge.
Professional Honors
- U.S. Department of Justice, Tax Division Assistant Attorney General Award for Training, 2019 and 2021
- Recognized by U.S. Attorney General as Outstanding Mentor, 2015
- U.S. Department of Justice, Tax Division Outstanding Attorney Award, 2013, 2015, 2016, 2019, 2020, 2021, 2022, 2023, 2024
- U.S. Department of Justice, Tax Division Special Act Award, 2025
Professional Associations and Memberships
- DC Bar Association - Member
- California Bar Association - Member
Admissions
- U.S. Supreme Court~United States
- U.S. Tax Court~United States
- U.S. Court of Federal Claims~United States
- U.S. District Court, Arizona~United States
- U.S. District Court, Northern District of California~United States
- U.S. District Court, Eastern District of California~United States
- U.S. District Court, Southern District of California~United States
- U.S. District Court, District of Colorado~United States
- U.S. Bankruptcy Court, District of Colorado~United States
- U.S. District Court, Southern District of Indiana~United States
- U.S. District Court, District of Maryland~United States
- U.S. District Court, District of Nevada
- U.S. District Court, District of Oregon~United States
- U.S. Bankruptcy Court, District of Oregon~United States
- U.S District Court, District of Utah~United States
- U.S. District Court, Western District of Washington
- U.S. Bankruptcy Court, Western District of Washington~United States
- California~United States
- Supreme Court of California~United States
- District of Columbia~United States
Education
- Yale Law School (JD) (2007)
- Dartmouth College (AB, summa cum laude) (2004)
Languages
- English
- Portuguese
- Spanish