Thomas V. Linguanti represents clients in complex tax controversies and tax litigation. He assists clients in determining the appropriate strategy in disputes with the US Internal Revenue Service during audit, alternative dispute resolution proceedings, and trial and appellate litigation. Tom represents both US and non-US corporations, as well as individuals. He began his tax litigation career as a trial and appellate attorney in the Tax Division of the US Department of Justice.
Tom has more than three decades of experience representing clients before the US Tax Court, federal district and bankruptcy courts, federal appeals courts, the US Court of Federal Claims, and in briefing matters before the US Supreme Court.
Tom is a frequent speaker at conferences and seminars on various aspects of federal tax controversies and negotiation strategies. He currently serves as a teaching faculty member of the National Institute for Trial Advocacy (NITA) and regularly teaches advocacy skills to government, public interest, and private firm lawyers. Before joining Morgan Lewis, Tom was a partner in the tax practice of another global law firm, where he was chair of its North American Tax Practice Group Management Committee.
Perrigo Company v. United States of America, 1:17-cv-00737-RJJ
CGG Americas, Inc. v. Commissioner, 147 T.C. 78 (2016)
Abbott Labs v. Commissioner, Tax Ct. No. 29307-11
Medtronic, Inc. v. Commissioner, Tax Ct. No. 6944-11
Sergio Garcia v. Commissioner, Tax Ct. No. 13469-10
Medtronic, Inc. v. Commissioner, Tax Ct. No. 17488-08
The May Dep’t Stores Co. v. Commissioner of Revenue, ATB Nos. C284427 & C284428 (2007)
The Dow Chemical Co. v. Department of Revenue, 359 III App. 3d 1 (2005) (lead counsel before ALJ)
Microsoft Corp. v. Commissioner, 311 F.3d 1178 (9th Cir. 2002), rev’g 115 T.C. 228 (2000)
Seagate Technology, Inc. v. Commissioner, Tax Ct. No. 15086-98