James "Jim" Dawson is a highly experienced tax litigation attorney and tax advisor in Holland & Knight's West Palm Beach office with extensive knowledge resolving Internal Revenue Service (IRS) controversies in audit, appeals and litigation. For more than 13 years, Mr. Dawson served as staff attorney for the IRS' Office of Chief Counsel, where he developed, prepared and tried complex factual and legal cases for trial before the U.S. Tax Court.
Mr. Dawson's practice focuses on representing corporations and individual taxpayers in federal tax audits and in federal tax litigation. He has experience appearing in all three of the major tax litigation forums: U.S. Tax Court, U.S. Court of Federal Claims and U.S. District Court. In these forums, he has represented taxpayers from the following industries: energy – nuclear, fossil, wind and solar; real estate and citrus, as well as high-net-worth individuals pertaining to estate, income tax and Report of Foreign Bank and Financial Accounts (FBAR) litigation.
Mr. Dawson's recent engagements include:
U.S. Tax Court
- Serving as lead counsel in a case of first impression challenging the IRS' directives on whether the cost of issuing bonds can be included in the basis, or capital investment, for tax purposes in obtaining tax credits for a low-income housing project under Internal Revenue Code Section 42; the case is particularly important in New York and other major U.S. cities where there is a crisis in the availability of affordable housing, and investors often require incentives to participate in this segment of residential development
- As co-counsel to a Fortune 500 company, turned a series of high-deficiency cases into refunds in excess of $100 million for the company
- As co-counsel to a Fortune 500 company, caused the IRS to concede its alleged deficiency in excess of $30 million in a high-basis, low-value asset case
U.S. Court of Federal Claims
- Served as lead and/or assisted counsel in five Section 1603 grant cases in various renewable energy projects that claimed more than $150 million in monetary relief
U.S. District Court for the Southern District of Florida
- Member of the firm's FBAR litigation team that challenged a $14 million assessment; the court, in a matter of first impression, found the assessment to be arbitrary and capricious; case is on appeal
- Served as lead counsel to a Fortune 500 company seeking more than $75 million in tax refunds pursuant to I.R.C. Section 172(f) related to nuclear waste disposal fees; assisted outside counsel when the case was appealed to the U.S. Court of Appeals for the Eleventh Circuit
Prior to joining Holland & Knight, Mr. Dawson spent the last 11 years as a staff attorney for one of the largest utility companies in the country, where he handled a number of complex tax controversy and tax litigation matters, alternative energy tax credits, and energy research and development credits.
Mr. Dawson is an adjunct professor at Florida Atlantic University in the Executive Masters Tax Program, having taught IRS Practice and Procedure and Writing for Tax Accountants.
- University of Miami School of Law, LL.M., Taxation
- University of Miami School of Law, J.D.
- University of Miami, B.B.A., Accounting
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. District Court for the Southern District of Florida
- U.S. Court of Appeals for the Eleventh Circuit
- Fellow, American College of Tax Counsel
- The J. Edgar Murdock American Inn of Court
- Florida Super Lawyers, Taxation, 2008
- Special Act Award, U.S. Department of Treasury, 1990, 1992, 1994-1996, 1999, 2000