James Dawson

James "Jim" Dawson helps corporations and individual taxpayers resolve high-stakes disputes with the IRS, from audits and administrative appeals through federal tax litigation. Drawing on more than 13 years with the IRS Office of Chief Counsel and 11 years as in-house counsel for a major utility company, Jim brings government, business and courtroom perspectives to complex federal tax controversies.

His federal tax litigation practice spans the U.S. Tax Court, U.S. Court of Federal Claims and U.S. district courts. Jim represents taxpayers in the energy, affordable housing, real estate and citrus industries, including on matters involving nuclear, fossil fuel, wind and solar energy. He also handles estate and income tax disputes, Report of Foreign Bank and Financial Accounts (FBAR) litigation, and advises clients on tax benefits and compliance under Puerto Rico's Act 60.

Jim represents clients in disputes where significant tax liabilities, refunds and tax positions are at stake. His matters have included serving as co-counsel to a Fortune 500 company in cases that resulted in refunds exceeding $100 million, as well as in a separate matter in which the IRS conceded an alleged deficiency exceeding $30 million. He also served as lead or assisting counsel in five Section 1603 grant cases involving renewable energy projects that claimed more than $150 million in monetary relief.

His litigation experience also includes serving as lead counsel in a U.S. Tax Court case of first impression involving the treatment of bond issuance costs in determining basis for low-income housing tax credits under Internal Revenue Code Section 42. Jim has handled litigation involving nuclear waste disposal fees and was part of the Firm's FBAR litigation team challenging a $14 million assessment that the district court found arbitrary and capricious.