Phillip Clifton
Texas Tower
845 Texas Avenue
Suite 4700
Houston, Texas 77002
Phillip represents corporations, partnerships, and high net-worth individuals at every stage in the lifecycle of a tax controversy: substantiating positions before examination, administrative proceedings in front of the Internal Revenue Service, and litigation in the Tax Court or district courts.
The following is a list of representative matters in which Phillip has assisted.
Experience Highlights
(S.D. Tex.) – Representing a multinational company in a federal income tax refund case involving the deductibility of a settlement payment
Representing a public corporation in an IRS examination of partnership basis items relating to an internal restructuring transaction
Advised a power company regarding the tax treatment of settlement proceeds following significant litigation
(D. Idaho) – Representing one of the country’s leading intermediaries in dispute with the IRS related to unauthorized disclosure of taxpayer information
(5th Cir.) – Authoring two amicus briefs on behalf of a high-net-worth client addressing when supervisory approval of penalties is considered timely under IRC § 6751(b)
Advise refinery on tax and environmental issues regarding carbon capture projects
Advise executives of acquired companies on substantiating tax return positions and represent executives under audit for tax issues stemming from business acquisitions including eligibility for the qualified small business stock exclusion and accounting for contingent earnouts
(IRS Audit) – Represent multinational conglomerate in examination of partnership basis items (ongoing)
Credentials
- Washington University School of Law, J.D., cum laude, 2021 (Primary Editor, Global Studies Law Review)
- Belmont University, 2018
- Texas
- EventDecember 13, 2025Wynn Las Vegas
- InsightNovember 19, 2025
Published in the November 2025 issue of Taxes Magazine
News & Insights
Published in the November 2025 issue of Taxes Magazine