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Thomas Crichton IV

Experience     |     Education     |     Recognition     |     Activities      |     Publications

Crichton, Thomas

Biography
Tom's law practice involves federal income tax matters, with particular emphasis in the natural resource, partnership, and corporate areas. His practice focuses primarily on business transactional tax advice in U.S. and international activities. He also advises on contested matters, including technical advice proceedings. He has represented clients before the National Office of the Internal Revenue Service in requests for ruling, and before the various appeals offices of the Internal Revenue Service, the United States Tax Court, and other tribunals concerning tax deficiency matters and claims for refund.


Representative Experience
Transactional
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  • Tax counsel in formation of successive multi-billion dollar private equity (opportunity) funds with U.S., foreign and tax-exempt participants and structuring of such funds’ domestic and international investments in real estate and real estate-related financial instruments
  • Represented large, privately held health care company in a proposed “reverse Morris Trust” spin-off/merger transaction
  • Represented publicly traded and privately held energy companies and funds in structuring domestic and international energy investments, both directly and through joint ventures
Contested Matters and Tax Litigation
  • Represented large, publicly traded, international energy company in administrative appeals proceedings with IRS
  • Represented publicly traded grocery company in administrative appeals proceedings with IRS
  • Represented Louisiana Land & Exploration Company in Tax Court proceedings involving deductibility of costs of offshore platforms and depletability of sulphur recovered from “sour gas,” with both issues resolved in the taxpayer’s favor
Prior results do not guarantee a similar outcome.

Education and Professional Background
  • Louisiana State University, J.D., 1972 (Order of the Coif; Editor in Chief, Louisiana Law Review, 1971 - 1972)
  • Louisiana State University, B.S., 1969 (Beta Alpha Psi; Omicron Delta Kappa)
  • Admitted to practice: Texas, 1972; Louisiana, 1972; District of Columbia, 1988; U.S. Tax Court; Court of Federal Claims; U.S. Courts of Appeals for the Fifth and Eleventh Circuits
Professional Recognition
  • "Texas Super Lawyer," Texas Monthly, 2004 - 2009
  • The Best Lawyers in America®  in tax law, 2003 - 2011
  • Who's Who Legal: Texas in corporate tax law, 2007 and 2008
Activities and Affiliations
  • Member: Natural Resources Committee, Chair, 1994 - 1996, Vice Chair, 1992 - 1994, and Government Submissions Committee, Section of Taxation, American Bar Association; Advisory Board for U.S. Income Tax Matters, Tax Management, Inc.
Publications and Presentations
  • "Partnerships - Taxable Income; Allocation of Distributive Shares; Capital Accounts," BNA Tax Management Portfolio, No. 712 (co-authored)


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Thomas Crichton IV
Partner
Trammell Crow Center
2001 Ross Avenue
Suite 3700
Dallas, TX 75201-2975

Tel  +1.214.220.7984
Fax  +1.214.999.7984
tcrichton@velaw.com

Industries/Practices
Energy

Federal Income Tax

Finance

Private Equity

Tax Litigation

Master Limited Partnerships (MLPs)