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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 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

  • Fellow, American College of Tax Counsel, 2012-present
  • 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
  • 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
Mr. Allison's speaking engagements also include:
  • Speaker, "The Scope of Attorney-Client Privilege After AD Investments," Administrative Practice Committee, ABA Tax Section, Washington, DC (June 18, 2014)
  • Panelist, Defending Taxpayer Penalties, Tax Executive Institute, IRS Audits and Appeals Seminar, New York, NY (May 2014)
  • Moderator, US Supreme Court and Appellate Tax Litigation: A Look at the Next Step, ABA Tax Section Meeting, Court Procedure and Practice Committee, Washington, DC (May 2014)
  • Panelist, "The Presentation of Evidence – Stone Age to Space Age", US Tax Court Program, Washington, DC (May 2014)
  • Speaker, US Tax Policy Issues, Columbia Undergraduate Law Review, New York, NY (April 2014)
  • Speaker, Roundtable Discussion on International Best Practices on Tax Mediation, Supreme Court of the Philippines, Philippine Judicial Academy, Manila, Philippines (October 18, 2013)
  • Speaker, "Alternative Dispute Resolution in US Tax Cases," ADMINISTRACIÓN Y JUSTICIA TRIBUTARIA, Bogota, Colombia (September 26, 2013)
  • Speaker, "Seventh Circuit Adopts Majority View on Valuation Misstatement Penalty," Administrative Practice Committee, ABA Tax Section (September 19, 2013)
  • Panelist, Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases, ABA Tax Section Meeting, Court Procedure and Practice Committee, Orlando, FL (January 2013)
  • Panelist, Motions in Limine in Tax Court Forums, ABA Section of Taxation 2012 May Meeting, Washington, D.C. (May 2012)
  • Panelist, Resolving Federal Tax Disputes: What Are My Alternatives, TEI Spring Seminar, Nashville, Tennessee (May 2012)
  • Moderator, Parallel Civil Tax Litigation and Criminal Investigations, Court Procedure and Practice Committee, ABA Tax Section Meeting, San Diego, CA (February 2012)
  • Panelist, Current Trends in Tax Litigation: Economic Substance, Debt/Equity, and Entity Choice, DC Bar Association, Tax Audits and Litigation Committee, Washington, D.C. (January 2012)
  • Moderator, Promoter and Material Advisor Litigation and Related Proceedings, Court Procedure and Practice Committee, ABA Tax Section Meeting, Boca Raton, FL (January 2011)
  • Panelist, Stipulations in the Tax Court, Court Procedure and Practice Committee, ABA Tax Section Meeting, San Antonio, TX (January 2010)
  • Panel Chair, Atypical Statutes of Limitations Issues, Court Procedure and Practice Committee, ABA Tax Section Meeting, Chicago, IL (September 2009)
  • Panel Chair, Transferee Liability Issues: The Pursuit of Taxes, Court Procedure and Practice Committee, ABA Tax Section Meeting, New Orleans, LA (January 2009)
  • Panel Chair, The Use of Jury Trials in Civil Tax Cases, Court Procedure and Practice Committee, ABA Tax Section Meeting, San Francisco, CA (September 2008)
  • Panel Chair, Settling TEFRA Cases, Court Procedure and Practice Committee, ABA Tax Section Meeting, Las Vegas, NV (January 2008)
  • Panel Chair, Cross Border Discovery in Civil Tax Controversies, Court Procedure & Practice Committee, ABA Tax Section Meeting, Vancouver, BC (September 2007)
  • Panelist, Unsettling Settlements: The Ambiguity of Section 162(f), Tax Executive Institute, Annual Conference, Scottsdale, AZ (October 24, 2006)
  • Panel Chair, Tax Shelter Promoter Litigation Issues, Court Procedure & Practice Committee, ABA Tax Section Meeting, Washington, D.C. (May 2006)
  • Panelist, Recent Developments and Trends in Tax Shelter Litigation in the U.S. Court of Federal Claims and Federal District Courts, Court Procedure & Practice Committee, ABA Tax Section Meeting, San Diego, CA (February 2006)
  • Panelist, Preclusion of Expert Witnesses, Court Procedure & Practice Committee, ABA Tax Section Meeting, Boston, MA (September 2004)

Awards & Rankings

  • Recommended in the 2012-2014 editions of The Legal 500
  • Ranked as a "Super Lawyer" by Super Lawyers magazine in 2013

Recent Media

  • Regular comments to media, such as the Wall Street Journal, Reuters, Bloomberg, Tax Notes Today and CCH Tax & Accounting
  • Contributor to Tax Analysts "Federal Circuit Reverses in ConEd and Disallows Leasing Deductions" (January 2013)
  • Contributor to ABA's, "Comments to Proposed Amendments to the Rules of United States Tax Court" (March 2012)
  • "Mark Allison Responds to Altria's Battle With the IRS", San Francisco Chronicle (July 21, 2011) 
  • Contributor to "ABA Section of Taxation Comments on Proposed Amendments to the Rules of the United States Tax Court" (March 2011)
  • Contributor to ABA's "Comments Concerning the Proposed Amendments to the Rules of the United States Tax Court" (May 2009)
  • Contributor to ABA's "Comments Concerning the Tax Court's Proposed Amendments regarding Privacy and Public Access to Electronic Case Files" (April 2007)
  • Contributor to ABA's "Comments Concerning the Proposed Amendments to the United States Tax Court Rule 173" (November 2006)
  • Contributor to ABA's "Comments Concerning the Tax Court's Proposed Interim Rule and Interim Procedures Regarding Electronic Filing Pilot Program" (February 2, 2006)
  • Contributor to ABA's "Comments on Proposed Regulations Relating to Changes to Collection Due Process Procedures" (December 27, 2005)
  • Important Developments for 2004: Court Procedure & Practice Committee, 58 The Tax Lawyer 75 (with Kevin Kenworthy) (Summer 2005)
  • Report on Current Developments, Court Procedure & Practice Committee, ABA Tax Section Meeting, Washington, D.C. (May 2005)
  • Report on Current Developments, Court Procedure & Practice Committee, ABA Tax Section Meeting, San Diego, CA (January 2005)
  • Report on Current Developments, Court Procedure & Practice Committee, ABA Tax Section Meeting, Boston, MA (September 2004)

Recent Publications

  • "Taxpayer Wins LILO Case in the Court of Federal Claims," Real Estate Finance Journal (with Lawrence M. Hill, April 2010)
  • "The New Battle In an Old War: Omissions From Gross Income," 126 Tax Notes 1227 (March 8, 2010)
  • "Treasury, IRS Continue Attack on Abusive Tax Transactions: Final Regulations for Reportable Transactions Issued," Derivatives Financial Products Report at 13 (with Lawrence M. Hill and Alexandra Minkovich) (September 2007)
  • "The IRS Reorganization: Programs and Initiatives of the New Large Case Division," 53 Admin. L. Rev. 679 (with Felix B. Laughlin) (2001)
  • Note, "The Hamas Deportation: Israel's Response to Terrorism During the Middle East Peace Process," 10 Am. U. J. Intl'l. & Pol'y 397 (1994)