Sheri A. Dillon

Sheri has tax litigation experience and has appeared before the US Tax Court, US district and appellate courts, and the US Court of Federal Claims. She represents corporate taxpayers, Tax Equity and Fiscal Responsibility Act (TEFRA) and Bipartisan Budget Act partnerships, partners, tax-exempt organizations, and global high-wealth taxpayers in the financial services, private equity, hedge fund, real estate, energy, manufacturing, and consumer products industries.

Specifically, Sheri’s recent experience includes challenges that involve economic substance, substance-over-form, and bona fide partnership issues; taxation of partnerships and partners; taxation of financial products; income tax accounting issues; cancellation of indebtedness income; employment tax issues; debt-equity classification; charitable contribution deductions; tax-exempt organizations, tax credits; and valuation. Sheri has also represented taxpayers and investors involved in promoter audit investigations.

Sheri is an active speaker who regularly presents on current tax issues at various professional organizations, including the American Bar Association Section of Taxation, Texas Federal Tax Institute, PLI, NYU Institute on Federal Taxation, Tax Executives Institute, Federal Bar Association, and DC Bar Section of Taxation. She previously taught partnership taxation at Catholic University of America’s Columbus School of Law and helped launch the University of the District of Columbia, David A. Clarke School of Law’s Low-Income Taxpayer Clinic, a program dedicated to providing legal services to low-income taxpayers. Sheri currently serves as a director and president of the Washington, DC Center for Public Interest Tax Law, whose mission is to provide pro bono tax services to the greater DC community.

• Decision pending on ownership of certain derivative contracts or underlying shares and mark-to-market accounting issues
• Negotiated a favorable settlement for a charitable contribution issue and dismissal of the Tax Court case on mootness grounds.
• Obtained full IRS concession on a partnership issue followed by stipulated decision entered by the Tax Court.
• Prevailed in the Court of Federal Claims on the proper allocation of items of long-term capital gain.
• Prevailed in a district court on issues involving economic substance and corporate-owned life insurance policies.
• Obtained full IRS concession on a pro bono matter where the IRS conceded the taxpayer’s entitlement to earned income tax credit followed by a stipulated decision entered by the Tax Court.