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Thomas Crichton IV
Thomas Crichton IV
Experience | Education | Recognition | Activities | Publications
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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.
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Representative Experience
Transactional View All
- Represented Statoil ASA in connection with its acquisition of Brigham Exploration Company for approximately $4.7 billion
- Represented Korea National Oil Corporation, KNOC, in connection with its acquisition of one-third of its Eagle Ford shale assets from Anadarko Petroleum for approximately $1.55 billion
- 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
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
View All
Legal 500 U.S. in domestic tax - central, 2011
Recognized in Texas Super Lawyers, 2004 - 2011
The Best Lawyers in America® in tax law, 2003 - 2011
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
- "The Fundamentals of Oil & Gas Taxation, Part II," 29th Annual Texas Federal Tax Institute, June 5, 2013
- "Partnerships - Taxable Income; Allocation of Distributive Shares; Capital Accounts," BNA Tax Management Portfolio, No. 712 (co-authored)
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Full Biography
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Trammell Crow Center 2001 Ross Avenue Suite 3700 Dallas, TX 75201-2975
Tel +1.214.220.7984
Fax +1.214.999.7984
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