Sheri A. Dillon

Partner

Sheri A. Dillon focuses on federal tax controversy matters, guiding clients through IRS examinations and appeals, the administrative claims process, and litigation. Sheri also counsels clients on a variety of business and tax-planning matters that involve acquisitions, dispositions, combinations, and debt restructuring and reorganizations, with a special focus on partnership transactions and closely held businesses.

Extended Profile

Sheri has tax litigation experience and has appeared before the US Tax Court, US district and appellate courts, and the US Court of Federal Claims. She represents corporate taxpayers, Tax Equity and Fiscal Responsibility Act (TEFRA) and Bipartisan Budget Act partnerships, partners, tax-exempt organizations, and global, high-wealth taxpayers in the financial services, private equity, real estate, energy, manufacturing, and consumer products industries.

Specifically, Sheri’s experience includes challenges that involve the economic substance, substance-over-form, and business purpose doctrines; taxation of partnerships and partners; taxation of financial products; income tax accounting issues; cancellation of indebtedness income; debt-equity classification; charitable contribution deductions; tax-free reorganizations; tax-exempt organizations, and valuation.

Sheri is an active speaker who regularly presents on current tax issues at various professional organizations, including the Tax Executives Institute, the Federal Bar Association, the American Bar Association Section of Taxation, and the DC Bar Section of Taxation. She previously taught partnership taxation at Catholic University of America’s Columbus School of Law and helped launch the University of the District of Columbia, David A. Clarke School of Law’s Low-Income Taxpayer Clinic, a program dedicated to providing legal services to low-income taxpayers. Sheri currently serves as a director and president of the Washington, DC Center for Public Interest Tax Law, whose mission is to provide pro bono tax services to the greater DC community.

selected representations

Negotiated a favorable settlement for a charitable contribution issue and dismissal of the Tax Court case on mootness grounds.
Obtained full IRS concession on a partnership issue followed by stipulated decision entered by the Tax Court.
Prevailed in the Court of Federal Claims on the proper allocation of items of long-term capital gain.
Prevailed in a district court on issues involving economic substance and corporate-owned life insurance policies.
Obtained full IRS concession on a pro bono matter where the IRS conceded the taxpayer’s entitlement to earned income tax credit followed by a stipulated decision entered by the Tax Court.