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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 for the Second Circuit

Mark D. Allison

Member, New York
(212) 379-6060
mallison@capdale.com | v-card | PDF

Mark D. Allison is a Member in Caplin & Drysdale's New York office.  Mr. Allison's practice involves complex federal, state, and cross-border tax controversy and litigation matters; related civil, criminal, and regulatory proceedings; and internal investigations. He represents multinational corporations, financial institutions, and individuals in proceedings before the Internal Revenue Service, the U.S. Department of Justice, the U.S. Attorneys' Office, and other government regulators.

An experienced trial attorney, Mr. Allison has litigated before the U.S. Courts of Appeals, the U.S. Tax Court, the U.S. Court of Federal Claims and in bench and jury trials in federal district court.  He also advises clients in pre- and post-transaction review and analysis of potential tax disputes for purposes of ASC 740, Schedule UTP and other regulatory reporting and internal risk management. Mr. Allison also serves as the general counsel to a New York City-based hedge fund manager.

Mr. Allison previously served as an attorney-advisor to the Honorable Julian I. Jacobs of the United States Tax Court, and as a law clerk to the Honorable Joseph C. Small of the New Jersey Tax Court.

Professional Activities

  • Adjunct Professor, New York University School of Law, 2009-present
  • Chair, Court Procedure & Practice Committee, American Bar Association, Tax Section, 2013-present (formerly Vice-Chair, 2011-2013; Chair for the Tax Court, 2007-2011; Appellate Practice, 2005-2007; Current Developments, 2004-2005)
  • 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

Awards & Rankings

  • The Legal 500, Recommended, 2012-Present
  • Super Lawyers, New York, 2013-Present

Recent News

Click here for a full list of media coverage.

Recent Speaking Engagements

  • 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
  • Chair, Court Procedure & Practice Committee, 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
  • 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
  • Speaker, Roundtable Discussion on International Best Practices on Tax Mediation, Supreme Court of the Philippines, Philippine Judicial Academy, October 18, 2013
  • Chair, Settling TEFRA Cases, American Bar Association, October 18, 2013
  • Chair, Tax Shelter Promoter Litigation Issues, American Bar Association, 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, Promoter and Material Advisor Litigation and Related Proceedings, American Bar Association, January 21, 2011
  • Moderator, The Scope and Nature of Section 6700 Litigation and Related Proceedings, American Bar Association, 2011 Midyear Meeting, 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.