Phillip J. Taylor

Mr. Taylor’s practice focuses on the resolution of federal income tax controversies with the IRS. He advises clients throughout all administrative phases of a controversy, including audit, administrative appeals, and alternative dispute resolution proceedings. Mr. Taylor also litigates tax cases in courts throughout the country. His clients include multinational corporations within the computer software and hardware, aerospace, defense, financial services, pharmaceutical, insurance, and oil and gas industries.

• Represented semiconductor manufacturer in Tax Court case that challenged the validity of section 482 cost-sharing regulations based on violations of the Administrative Procedure Act.
• Represented client in Tax Court case involving statutory interpretation issues concerning the application of section 167(h) to geophysical expenses relating to the exploration for oil and gas.
• Represented four clients in cases in which Tax Court refused to impose transferee liability with respect to sale of stock transaction that IRS sought to recast using substance of form principles.
• Represented clients in IRS appeal of Tax Court decisions in Second Circuit and Ninth Circuit.
• Represented consumer electronics retailer in refund suit seeking to recover refunds and obtain class action certification relating to erroneously collected communications excise tax in the United States Court of Federal Claims.
• Represented numerous multinational companies in transfer pricing disputes during IRS examinations and before IRS Appeals.