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Mark D. Allison
Caplin & Drysdale
Mark D. Allison Member

mallison@capdale.com

P: (212) 379-6060

F: (212) 379-6001

New York Office

Professional Activities

  • Member, Planning Committee, New York University 9th Annual Tax Controversy Forum
  • Member,  Appointments to the Tax Court Committee, American Bar Association, Taxation Section, 2015-present
  • Former Chair, Court Procedure & Practice Committee, American Bar Association, Tax Section, 2013-2015; (previously Vice-Chair, 2011-2013; Chair for the Tax Court, 2007-2011; Appellate Practice, 2005-2007; Current Developments, 2004-2005)
  • Adjunct Professor, New York University School of Law, 2009-present
  • Instructor, Tax Law VITA Training, West Point Military Academy, 2016-present
  • Articles Editor, The Tax Lawyer, 2011-present
  • Fellow, American College of Tax Counsel, 2012-present
  • Board of Advisors, Low Income Taxpayer Clinic, Legal Aid Society, 2007-2011
  • Member, New York State Bar Association, Tax Section
  • Board of Advisors, Duke Law School Low Income Taxpayer Clinic, 2006-2008
  • Former Associate Justice, B'nai B'rith International Supreme Court, 2003-2004

Practice Areas

Awards & Rankings

  • The Legal 500, Recommended, 2012-Present
  • The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2015-Present
  • Super Lawyers, New York, 2013-Present

Recent News

Click here for a full list of media coverage.

Recent Speaking Engagements

  • Panelist, From The Experts: Tax Controversy and Tax Litigation Update, NYU 77th Institute on Federal Taxation, November 11, 2018
  • Moderator, From The Experts: Tax Controversy and Tax Litigation Update, NYU 77th Institute on Federal Taxation, October 21, 2018
  • Speaker, The Impact of the U.S. Tax Reform on Brazilian Individuals, Companies and Investments, Brazil Tax Conference 2018, April 12, 2018
  • Panelist, From The Experts: IRS Representation Tools, Techniques, and Defensive Strategies—Civil and Criminal Tax Update, NYU 76th Institute on Federal Taxation, October 22, 2017
  • Presenter, Questions About Questions: How to Interview a Witness, ABA Section of Taxation, 2017 Joint Fall CLE Meeting, September 15, 2017
  • Micro-Captive Transactions: What's Next and How Can You Prepare, AICPA, August 24, 2017
  • Panelist, TOIs, Investigations, and Campaigns – the Tools of the IRS, Delaware Captive Insurance Association Spring Forum, May 8, 2017
  • Speaker, Captive Insurance: New IRS Tax Reporting Regime, AICPA, December 19, 2016
  • Speaker, Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, Bloomberg BNA, December 9, 2016
  • Panelist, Hot Audit/Controversy Issues, NYU 75th Institute on Federal Taxation, November 15, 2016
  • Panelist, From The Experts: IRS Representation Tools, Techniques And Defensive Strategies – Civil & Criminal Tax Update, NYU 75th Institute on Federal Taxation, November 13, 2016
  • Panelist, From The Experts: IRS Representation Tools, Techniques And Defensive Strategies – Civil & Criminal Tax Update, NYU 75th Institute on Federal Taxation, October 23, 2016
  • Panelist, Hot Audit/Controversy Issues, NYU 75th Institute on Federal Taxation, October 23, 2016
  • Representing Taxpayers Who Can't, or Won't, Pay: The Ins and Outs of Collection Due Process Cases, 8th Annual Tax Controversy Forum, NYU School of Professional Studies, June 24, 2016
  • Panelist, Fines, Penalties and Costs to Settle Litigation, American Bar Association Section of Taxation, May 6, 2016
  • Speaker, Litigating Partnership Tax Cases Under the New Partnership Tax Rules of the Bipartisan Budget Act of 2015, American Bar Association Section of Taxation, May 6, 2016
  • Speaker, The New Partnership Audit Regime, 2016 Nashville TEI Spring Seminar, Tax Executives Institute, Inc., May 5, 2016
  • Speaker, Nuts & Bolts of Tax Court Litigation: Post-Trial, ABA Tax Section, January 30, 2016
  • Panelist, From the Experts: IRS Representation Tools, Techniques and Defensive Strategies - Civil & Criminal Tax Update, NYU 74th Institute on Federal Taxation, October 25, 2015
  • Speaker, Examinations of TEFRA Partnership, American Law Institute Continuing Legal Education (ALI CLE), Handling a Tax Controversy 2015: Current Trends in Civil Tax Controversies and Litigation, October 8, 2015
  • Speaker, IRS Audits and Appeals in the Issue Focused Exam Era, 2015 Nashville TEI Spring Seminar, May 20, 2015
  • Panelist, Cross Border Privileges Issues, American Bar Association, 2015 May Meeting, May 8, 2015
  • Chair, Court Procedure and Practice Roundtable Discussion, American Bar Association, 2015 May Meeting, May 8, 2015
  • Panelist, Pre-Trial Planning & Judicial Precedence, American Bar Association, 2015 Midyear Meeting, January 30, 2015
  • Panelist, From the Experts: Civil & Criminal Tax Controversy and Tax Litigation Update, New York University School of Professional Studies, 73rd Institute on Federal Taxation, November 16, 2014
  • Speaker, Cascading Toward Extinction? The Continuing Assault on Privilege, Tax Executive Institute, Nashville Chapter, October 22, 2014
  • Panelist, From the Experts: Civil and Criminal Tax Controversy and Tax Litigation Update, New York University, 73rd Institute on Federal Taxation, October 19, 2014
  • Panelist, Tax Court Procedures: Pretrial Practices (Motions, Pretrial Memoranda, Stipulations of Fact, Exhibits and Witness Subpoenas), American Law Institute (ALI) CLE, Handling a Tax Controversy: Audit, Appeals, Litigation, & Collections, October 17, 2014
  • Panelist, It's a Privilege, or Is It: Privilege Issues in Tax Cases, American Bar Associaton, 2014 Joint Fall CLE Meeting, September 19, 2014
  • Chair, Court Procedure and Practice Roundtable Discussion, American Bar Association, 2014 Joint Fall CLE Meeting, September 19, 2014
  • Speaker, The Scope of Attorney-Client Privilege After AD Investments, American Bar Association, June 18, 2014
  • Speaker, Defending Taxpayer Penalties, Tax Executives Institute, May 22, 2014
  • Moderator, U.S. Supreme Court and Appellate Tax Litigation: A Look at the Next Step, American Bar Association, 2014 May Meeting, May 9, 2014
  • Moderator, Court Procedure & Practice Roundtable Discussion - The Trial Countdown, American Bar Association, 2014 May Meeting, May 9, 2014
  • Chair, Court Procedure & Practice Committee, American Bar Association, 2014 May Meeting, May 9, 2014
  • Panelist, The Presentation of Evidence - Stone Age to Space Age, U.S. Tax Court, May 1, 2014
  • Speaker, Dodd-Frank Tax Issues, Columbia University, April 30, 2014
  • Chair, Tax Shelter Promoter Litigation Issues, American Bar Association, October 18, 2013
  • Chair, Settling TEFRA Cases, American Bar Association, October 18, 2013
  • Speaker, Roundtable Discussion on International Best Practices on Tax Mediation, Supreme Court of the Philippines, Philippine Judicial Academy, October 18, 2013
  • Speaker, Alternative Dispute Resolution in U.S. Tax Cases, Instituto Colombiano de Derecho Tributario's International Forum of Administration and Tax Justice, September 26, 2013
  • Speaker, Seventh Circuit Adopts Majority View on Valuation Misstatement Penalty, American Bar Association, September 18, 2013
  • Panelist, Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases, American Bar Association, 2013 Midyear Meeting, January 25, 2013
  • Panelist, Motions in Limine in Tax Court Forums, American Bar Association, 2012 May Meeting, May 11, 2012
  • Speaker, Resolving Federal Tax Disputes: What Are My Alternatives, Tax Executives Institute, May 1, 2012
  • Moderator, Parallel Civil Tax Litigation and Criminal Investigations, American Bar Association, 2012 Midyear Meeting, February 17, 2012
  • Panelist, Current Trends in Tax Litigation: Economic Substance, Debt/Equity, and Entity Choice, District of Columbia Bar Association, January 19, 2012
  • Moderator, The Scope and Nature of Section 6700 Litigation and Related Proceedings, American Bar Association, 2011 Midyear Meeting, January 21, 2011
  • Moderator, Promoter and Material Advisor Litigation and Related Proceedings, American Bar Association, January 21, 2011
  • Speaker, Stipulations in the Taxt Court, American Bar Association, January 11, 2010
  • Chair, Atypical Statutes of Limitations Issues, American Bar Association, September 10, 2009
  • Chair, Transferee Liability Issues: The Pursuit of Taxes, American Bar Association, January 10, 2009
  • Chair, The Use of Jury Trials in Civil Tax Cases, American Bar Association, September 10, 2008
  • Chair, Cross-Border Discovery in Civil Tax Controversies, American Bar Association, September 10, 2007
  • Speaker, Unsettling Settlements: The Ambiguity of Section 162(f), Tax Executives Institutes, October 24, 2006
  • Speaker, Recent Developments and Trends in Tax Shelter Litigation in the U.S. Court of Federal Claims and Federal District Courts, American Bar Association, February 10, 2006
  • Speaker, Preclusion of Expert Witnesses, American Bar Association, September 10, 2004

Click here for a full list of speaking engagements.

Recent Publications

Click here for a full list of publications.

Education

  • LL.M., New York University School of Law, 1996
  • J.D., American University Washington College of Law, 1995, summa cum laude, Arthur Bakalar Award, Note & Comment Editor, American University Journal of International Law & Policy
  • M.A., American University, 1992
  • B.A., Claremont McKenna College, 1990

Bar and Court Admissions

  • New York
  • District of Columbia
  • U.S. Court of Federal Claims
  • U.S. Tax Court
  • U.S. Court of Appeals, Second Circuit
  • U.S. District Court, Southern District of New York
  • U.S. District Court, Eastern District of New York
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