Denise Mudigere
Partner
Overview
Denise M. Mudigere is a tax attorney in Holland & Knight's Dallas office. Ms. Mudigere focuses her practice on representing individuals and entities in all stages of federal civil tax disputes.
Ms. Mudigere represents clients in Internal Revenue Service (IRS) examinations, administrative appeals and litigation. She has settled multiple tax disputes in administrative proceedings and with IRS legal counsel, avoiding litigation in court when possible.
In addition, Ms. Mudigere is active in the pro bono community and has assisted in several tax matters for low-income individuals.
Prior to joining Holland & Knight, Ms. Mudigere worked at an international law firm with a diversified tax practice.
While in law school, Ms. Mudigere served as editor-in-chief of the SMU Law Review and studied at University College in Oxford.
Representative Experience
- Represented a multinational company in IRS administrative proceedings in connection with IRS attempts to reclassify debt as equity
- Represented a multinational company in connection with an IRS examination of tax issues related to the takeover of a publicly traded company and the subsequent restructuring of its stock acquisition
- Represented a large multinational company in summons enforcement litigation regarding the company's assertion of privilege for tax advice given during high-stakes refinancing and restructuring transactions, including appellate briefing and coordination of international privilege review efforts; U.S. Court of Appeals for the Second Circuit opinion affirmed taxpayer's position and set favorable precedent for protection of tax and business advice
- Represented taxpayers in U.S. Tax Court litigation in connection with IRS efforts to convert private equity and hedge fund capital gains into ordinary income
- Successfully negotiated settlements for numerous U.S. taxpayers in connection with IRS challenges to losses arising from investments in distressed assets
- Obtained a favorable U.S. Tax Court ruling on all issues for former shareholders in litigation involving an IRS determination of transferee liability arising from the sale of a family business
- Successfully defended against accuracy-related penalties and raised a reasonable cause defense in U.S. Tax Court for taxpayer that acted reasonably and in good faith in deducting losses the IRS challenged
- Assisted a major corporation in an accurate assessment of potential federal and state successor liability taxes related to the corporation's initial acquisition of certain assets and a pending merger agreement; successfully negotiated with taxing authorities to cancel successor liability and release all liens and levies
- Successfully negotiated a settlement of less than $50,000 for a taxpayer in an administrative appeals mediation regarding an IRS challenge of the taxpayer's net operating loss deductions, with more than $14 million at issue
- Assisted a foreign federal government in drafting fair tax collection legislation
- Assisted a testifying expert witness on tax litigation procedure, trial strategy and ethics in connection with a confidential arbitration arising out of the high-profile Long Term Capital Holdings case
Credentials
- Southern Methodist University Dedman School of Law, J.D., cum laude
- Southwestern Assemblies of God University, B.A., summa cum laude
- Texas
- U.S. Tax Court
- Dallas Bar Foundation (DBF), Fellow
- Plano Chamber of Commerce, Women's Division Board of Directors, 2022-2023
- American Bar Association, Section of Taxation
- Love Heals, Board of Directors
- The Best Lawyers in America guide, Dallas Tax Law Ones to Watch, 2021-2023
- Best Lawyers in Dallas, D Magazine, 2021
- Rising Star, Texas Super Lawyers, 2016-2020
- Best Lawyers Under 40, D magazine, 2019, 2021
