Phillip J. Taylor has helped clients seeking to successfully resolve cases before the United States Tax Court, United States Court of Federal Claims, United States Courts of Appeals, and numerous other federal and state courts throughout the country. Mr. Taylor has participated in a wide variety of dispute resolution matters involving a broad spectrum of international and domestic issues, including issues related to transfer pricing, research credits, challenges to the validity of regulations, statutory interpretation of Internal Revenue Code provisions, transferee liability matters, and the application of substance over form, economic substance, and step transaction doctrines.
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.
Representative Legal Matters
- 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.
- District of Columbia~United States (2016)
- New York~United States (2008)
- Harvard Law School (J.D.) (2007)
- Rochester Institute of Technology (B.S. Business Administration High Honors) (2003)