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TP Minds West Coast
December 4 - 5, 2024
Hyatt Regency San FranciscoSan Francisco

Steven R. Dixon
Partner at STEPTOE


Steve Dixon has been litigating federal tax cases for corporate and individual taxpayers for almost 20 years. He has represented Fortune 500 taxpayers in high-profile trials before the Tax Court, the Court of Federal Claims, and in federal district court. Steve’s practice often involves complex transfer-pricing controversies; he represented one taxpayer in a multi-billion-dollar transfer-pricing case in the Tax Court. However, his controversy practice is diverse and has included disputes about intangible asset valuation, statutory interpretation, tax accounting, excise taxes, statutes of limitation, debt-equity determinations, and loss deductions. He has represented taxpayers in the consumer products, technology, retail, energy, defense, real estate development, health care, transportation, and banking industries.

Steve has been recognized as a Tax Controversy Leader by International Tax Review as well as in Legal 500 United States for tax controversy. Steve has authored scores of motions and briefs and is an experienced courtroom litigator with experience in everything from opening statements and direct examination to the cross-examination of expert witnesses. Steve also represents taxpayers in controversies before IRS Appeals and at Exam. He advises clients on other strategic tax issues, excise taxes, privilege and work product issues, and litigation strategy.

Steve publishes on myriad tax subjects, including transfer-pricing regulations, interest netting, partnerships, deference, and the rules governing tax practice. He has authored articles in the Journal of Taxation and Business Entities, among other publications, and regularly comments on tax litigation in Tax Notes, Bloomberg, and Law360. Steve regularly presents on tax controversy and litigation topics in a variety of forums, including before various chapters of the Tax Executives

Agenda Sessions

  • Revisiting and Revising your Transfer Pricing

  • Some Vagaries in the Contours of the Arm’s-Length Hypothetical

  • The Rise of Sustainability & ESG in Taxation & TP