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    • Apr 08, 2021

Sean M. Akins

Partner

Washington +1 202 662 5062

  • About
  • Representative Matters
  • Credentials
  • About

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

    Sean 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.

    In addition to litigating tax matters, Sean also provides strategic advice with respect to navigating the Internal Revenue Service administratively. This involves representing clients before the IRS Office of Appeals, in Fast Track proceedings, in connection with standard and CAP-based audits, and in the obtaining of private rulings from the IRS on substantive issues. Sean also assists clients in responding to Congressional and other administrative tax investigations.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • Counsel to National Hockey League team in in successful trial before the U.S. Tax Court involving limitations as to the deductibility of certain business expenses. Jacobs v. Commissioner, 148 T. C. NO. 24 (2017).
    • Counsel to national online retailer/marketplace leader in novel state sales tax litigation currently pending before an administrative law court.
    • Counsel to national homebuilding company in successful trial involving the application of the completed contract method of accounting. Successfully defended against Government’s appeal before the Ninth Circuit. Shea Homes, Inc. v. Commissioner, 142 T.C. NO. 3 (2014), aff’d 834 F.3d 1061 (9th Cir. 2016).
    • 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.

    • 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.   
    • 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.

    Areas of Expertise

  • Credentials
    Education
    • Cornell Law School, J.D., 2007
        • magna cum laude
        • Order of the Coif
        • Cornell Law Review, Admissions Editor
    • The George Washington University, B.A., 2003
        • cum laude
        • special honors
    Bar Admissions
    • District of Columbia
    • Maryland
    • U.S. Court of Federal Claims
    • U.S. Tax Court
    Accolades
    • Law360, Tax "Rising Star" (2020)
    • Legal 500 US, Tax - US Taxes - Contentious (2017)
    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)

    Areas of Expertise

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