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Sean Akins
Sean M. Akins
Partner
Washington +1 202 662 5062 sakins@cov.com Download V-card

For nearly a decade, Sean Akins has advised corporations, partnerships, international organizations and tax-exempt entities on Federal tax litigation and controversy matters. Mr. Akins has extensive experience litigating before the Tax Court, Court of Federal Claims, and the U.S. District and Appellate Courts.

Mr. Akins is co-author of Kafka, Cavanagh, & Akins, Litigation of Federal Civil Tax Controversies, 2d ed., the leading two-volume treatise on the litigation of tax cases in the United States.

  • Counsel to national homebuilding company in successful trial involving the application of the completed contract method of accounting. Government appeal of taxpayer’s victory is pending before the Ninth Circuit. Shea Homes, Inc. v. Commissioner, U.S. Tax Court Nos. 292771-09, 1400-10 and 1401-10.
  • Counsel to construction industry company in litigation before the U.S. Tax Court involving worthlessness deduction of a partnership interest. Although Government had proposed a tax deficiency, ultimately secured concession from Government prior to trial resulting in a refund to taxpayer. JELD-WEN v. Commissioner, U.S. Tax Court No. 003055-14.
  • Counsel to National Hockey League team in pending tax litigation before the U.S. Tax Court involving limitations as to the deductibility of certain business expenses. Jacobs v. Commissioner, U.S. Tax Court No. 019009-15.
  • Counsel to publicly traded healthcare company involving representation before the IRS Office of Appeals on income accrual issues. Secured complete concession from Government.
  • Lead counsel to owners of homebuilding corporation in pending tax litigation before the U.S. Court of Federal Claims involving the application of the statute of limitations to various refund claims filed with the IRS. Shea, et al v. U.S., Court of Federal Claims No. 1:15-cv-00438-TCW.
  • Counsel to publicly traded pharmaceutical company in the preparation of transfer pricing files for potential IRS audit and litigation.
  • Lead counsel to a TEFRA partnership in litigation before the U.S. Tax Court involving income recognition based on partnership adjusted basis. Secured concession from Government prior to trial. SFHB I, LLC v. Commissioner, U.S. Tax Court No. 03594-13.
  • Counsel to major pharmaceutical company in litigation before the U.S. Tax Court involving the deductibility of a merger termination fee. Secured favorable settlement from Government. Inamed Corporation and Subsidiaries v. Commissioner, U.S. Tax Court No. 021850-12.

Memberships and Affiliations

  • Nolan Fellow (2014-2015), ABA Section of Taxation
  • J. Edgar Murdock American Inns of Court (U.S. Tax Court), Associate Member
  • ABA Section of Taxation, Court Practice and Procedures Committee, Ethics Subcommittee Chair (2014-2015); Insurance Companies Committee, Co-Vice Chair (2010-2011)