Phillip Clifton

Associate

Tax

Overview

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.

Experience

(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
(5^th Cir.) – Authored amicus briefs on behalf of a high-net-worth client addressing when supervisory approval of penalties is timely under Section 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)