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For over 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 U.S. 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.
In addition to litigating tax matters, Mr. Akins 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. Mr. Akins also assists clients in responding to Congressional and other administrative tax investigations.
- 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.
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)
August 14, 2018, Covington Alert
New restrictions on the deductibility of certain payments will require companies facing government investigations to pay close attention to the tax treatment of any settlement or court judgment, and to address this treatment in their negotiations with regulatory agencies. There is a risk under new tax rules that the amount paid to resolve these disputes may be ...
Amicus Argues Starr International Erroneous Refund Suit Was Untimely
January 4, 2018, 2018 TNT 6-16
2018, Kafka, Cavanagh & Akins, Second Edition, Volumes 1 and 2
Best Practices: Briefs and Memorandums
December 5, 2017, IRS LITC Annual Grantee Conference
June 29, 2017, Covington Alert
In a case that could have wide-ranging effect across the sports industry and potentially beyond, the U.S. Tax Court ruled on June 26, 2017, that the Boston Bruins were allowed to deduct 100 percent of the costs of meals that they served to their players and other employees at hotels while traveling for road games. The IRS had argued that only 50 percent of those ...
Effective Oral Presentations in Tax Matters
June 2017, Tax Executive Institute, Audits and Appeals Meeting
Reasoned Decision Making Under the APA: Holding the IRS to a Reasonable Standard
2017, American Bar Association, Mid-Year Meeting
Covington Promotes 13 New Partners
October 3, 2016
WASHINGTON—Covington has promoted 13 lawyers to its partnership. “Our new partners reflect the excellence, strengths, and diversity of the firm and will play important roles in the firm for decades to come and will help drive our key practices to even greater success in the years ahead,” said Timothy Hester, Covington’s chair. The new partners, who are based in ...
Evaluating the LB&I Reorganization
2016, Tax Executives Institute Mid-Year Meeting
So You Think You Can Negotiate? Getting to Closure
2016, Tax Executives Institute Audits and Appeals Seminar
IT’S ALIVE! – Exploring Exceptions to the Statutes of Limitations to ‘Revive’ Otherwise Time-Barred Claims
2016, American Bar Association Annual Meeting
Managing Privilege
2015, Tax Executives Institute National Tax Controversy Meeting
Exempt Organizations - Tax Controversies and Audits
2015, 51st Annual Washington, Non-Profit Legal & Tax Conference
Equitable Doctrines in Tax Litigation
2015, Federal Bar Association Tax Law Conference
Litigating the Administrative Procedures Act – Part 2
2014, ABA Tax Section Conference, Court Procedure and Practice Committee
Reaching Agreement – Settling Tax Cases in Litigation
2014, ABA Tax Section Conference, Court Procedure and Practice Committee
Managing FBAR Requirements
2013, Association of Financial Professionals Annual Meeting
Tax Risk Management – Responding to Emerging Tax Controversy Trends
2013, Nashville Chapter Tax Executive Institute Meeting
Tax Practice Ethical Considerations for In-House Tax Executives
2013, Central Wisconsin Tax Executive Institute Meeting
Strategic Considerations for Administrative Resolutions
2013, Denver Chapter Tax Executive Institute Meeting
2013, The Tax Executive
Tax Practice Ethical Considerations for In-House Tax Executives
2013, Denver Chapter Tax Executive Institute Meeting
Keeping the Cat in the Bag – Motions in Limine in Tax Court Forums
2012, ABA Tax Section Conference, Court Procedure and Practice Committee
Representing Your Client Before the Tax Court
2012, ABA Tax Section Conference, Court Procedure and Practice Committee
- Legal 500 US, Tax - US Taxes - Contentious (2017)