Mark D. Allison is a member in Caplin & Drysdale's New York office. Prior to joining Caplin & Drysdale, Mr. Allison was practicing tax controversy and litigation at an international law firm. In addition, he previously served as an attorney-advisor to the Honorable Julian I. Jacobs of the United States Tax Court, and before that a law clerk to the Honorable Joseph C. Small of the New Jersey Tax Court.
Services
Mr. Allison's practice involves complex federal and state tax controversy and litigation matters, related civil, criminal and regulatory proceedings, and internal investigations. He represents multinational corporations, financial institutions and individuals in proceedings before the Internal Revenue Service, the Department of Justice, the U.S. Attorneys' Office and other government regulators. He has presented in litigation before the United States Tax Court, the United States Court of Federal Claims and in bench and jury trials in federal district court.
Professional Activities
- Adjunct Professor, New York University School of Law (2009-present)
- Vice Chair, Court Procedure & Practice Committee, American Bar Association, Tax Section (2011 - present)
- Former Subcommittee Chair for the Tax Court (2007-2011), Appellate Practice (2005-2007), Current Developments (2004-2005)
- Articles Editor of The Tax Lawyer (2011 to present)
- Board of Advisors, Low Income Taxpayer Clinic, Legal Aid Society (2007-present)
- New York State Bar Association, Tax Section
- Board of Advisors, Duke Law School Low Income Taxpayer Clinic (2006-2008)
- Former Associate Justice, B'nai B'rith International Supreme Court (2003-2004)
Mr. Allison's speaking engagements also include:
- Panelist, Motions in Limine in Tax Court Forums, ABA Section of Taxation 2012 May Meeting, Washington, DC (May 2012)
- Panelist, Resolving Federal Tax Disputes: What Are My Alternatives, TEI Spring Seminar, Nashville, Tennessee (May 2012)
- Moderator, Parallel Civil Tax Litigation and Criminal Investigations, Court Procedure and Practice Committee, ABA Tax Section Meeting, San Diego, CA (February 2012)
- Panelist, Current Trends in Tax Litigation: Economic Substance, Debt/Equity, and Entity Choice, DC Bar Association, Tax Audits and Litigation Committee, Washington, DC (January 2012)
- Moderator, Promoter and Material Advisor Litigation and Related Proceedings, Court Procedure and Practice Committee, ABA Tax Section Meeting, Boca Raton, FL (January 2011)
- Panelist, Stipulations in the Tax Court, Court Procedure and Practice Committee, ABA Tax Section Meeting, San Antonio, TX (January 2010)
- Panel Chair, Atypical Statutes of Limitations Issues, Court Procedure and Practice Committee, ABA Tax Section Meeting, Chicago, IL (September 2009)
- Panel Chair, Transferee Liability Issues: The Pursuit of Taxes, Court Procedure and Practice Committee, ABA Tax Section Meeting, New Orleans, LA (January 2009)
- Panel Chair, The Use of Jury Trials in Civil Tax Cases, Court Procedure and Practice Committee, ABA Tax Section Meeting, San Francisco, CA (September 2008)
- Panel Chair, Settling TEFRA Cases, Court Procedure and Practice Committee, ABA Tax Section Meeting, Las Vegas, NV (January 2008)
- Panel Chair, Cross Border Discovery in Civil Tax Controversies, Court Procedure & Practice Committee, ABA Tax Section Meeting, Vancouver, BC (September 2007)
- Panelist, Unsettling Settlements: The Ambiguity of Section 162(f), Tax Executive Institute, Annual Conference, Scottsdale, AZ (October 24, 2006)
- Panel Chair, Tax Shelter Promoter Litigation Issues, Court Procedure & Practice Committee, ABA Tax Section Meeting, Washington, DC (May 2006)
- Panelist, Recent Developments and Trends in Tax Shelter Litigation in the U.S. Court of Federal Claims and Federal District Courts, Court Procedure & Practice Committee, ABA Tax Section Meeting, San Diego, CA (February 2006)
- Panelist, Preclusion of Expert Witnesses, Court Procedure & Practice Committee, ABA Tax Section Meeting, Boston, MA (September 2004)
Recent Media
- Contributor to ABA's, "Comments to Proposed Amendments to the Rules of United States Tax Court" (March 2012)
- "Mark Allison Responds to Altria's Battle With the IRS", San Francisco Chronicle (July 21, 2011)
- Contributor to "ABA Section of Taxation Comments on Proposed Amendments to the Rules of the United States Tax Court" (March 2011)
- Contributor to ABA's "Comments Concerning the Proposed Amendments to the Rules of the United States Tax Court" (May 2009)
- Contributor to ABA's "Comments Concerning the Tax Court's Proposed Amendments regarding Privacy and Public Access to Electronic Case Files" (April 2007)
- Contributor to ABA's "Comments Concerning the Proposed Amendments to the United States Tax Court Rule 173" (November 2006)
- Contributor to ABA's "Comments Concerning the Tax Court's Proposed Interim Rule and Interim Procedures Regarding Electronic Filing Pilot Program" (February 2, 2006)
- Contributor to ABA's "Comments on Proposed Regulations Relating to Changes to Collection Due Process Procedures" (December 27, 2005)
- Important Developments for 2004: Court Procedure & Practice Committee, 58 The Tax Lawyer 75 (with Kevin Kenworthy) (Summer 2005)
- Report on Current Developments, Court Procedure & Practice Committee, ABA Tax Section Meeting, Washington, DC (May 2005)
- Report on Current Developments, Court Procedure & Practice Committee, ABA Tax Section Meeting, San Diego, CA (January 2005)
- Report on Current Developments, Court Procedure & Practice Committee, ABA Tax Section Meeting, Boston, MA (September 2004)
Recent Publications
- "Taxpayer Wins LILO Case in the Court of Federal Claims," Real Estate Finance Journal (with Lawrence M. Hill, April 2010)
- "The New Battle In an Old War: Omissions From Gross Income," 126 Tax Notes 1227 (March 8, 2010)
- "Treasury, IRS Continue Attack on Abusive Tax Transactions: Final Regulations for Reportable Transactions Issued," Derivatives Financial Products Report at 13 (with Lawrence M. Hill and Alexandra Minkovich) (September 2007)
- "The IRS Reorganization: Programs and Initiatives of the New Large Case Division," 53 Admin. L. Rev. 679 (with Felix B. Laughlin) (2001)
- Note, "The Hamas Deportation: Israel's Response to Terrorism During the Middle East Peace Process," 10 Am. U. J. Intl'l. & Pol'y 397 (1994)