Timothy Jacobs

Timothy L. Jacobs’s practice focuses on all areas of federal income tax law, with particular emphasis on tax controversy and litigation matters. Tim served as an attorney-advisor to the Hon. Michael B. Thornton (2003-2005) and the Hon. Robert P. Ruwe (2001-2003) on the US Tax Court, and has particular knowledge in the areas of Tax Court practice, procedure, and litigation.

Tim is admitted to practice in the US Supreme Court, US Tax Court, the US Court of Federal Claims and the US Courts of Appeals for the Third, Fourth, Sixth and Federal Circuits.

Experience:

• Successfully tried foreign tax credit case in the US Tax Court involving the creditability of the UK Windfall Tax. In a unanimous 9-0 opinion, the US Supreme Court agreed with this holding based on the Tax Court record and opinion.
• Litigating cases in US Tax Court and handled IRS appeals involving alleged “intermediary” transactions covered by IRS Notice 2001-16 and Notice 2008-111.
• Johnson v. Comm’r, Docket Nos. 19768-11, 19769-11, 19770-11 (settled with substantial concession by IRS).
• Represent and advise taxpayers in controversies involving the Treasury’s Section 1603 grant program. Litigating Section 1603 cases in the US Court of Federal Claims and US Court of Appeals for the Federal Circuit.
• Represent and advise taxpayers with respect to IRS challenges to partnerships with federal and state tax credits. Commentator on the leading federal tax credit partnership case in Historic Boardwalk Hall, LLC v. Comm’r, 694 F.3d 425 (3d Cir. 2012).
• Represents clients in tax litigation in US Tax Court, federal district courts, US Court of Federal Claims, US Courts of Appeals, and the US Supreme Court.
• Represents corporate, partnership, and individual clients in IRS administrative and Appeals Office proceedings.
• Represents clients in obtaining private letter rulings, pre-filing agreements, and technical advice memoranda.

EDUCATION:

• LL.M., Taxation, New York University, 2001
• JD, Duquesne University, magna cum laude, 2000
• BA, Washington & Jefferson College, cum laude, 1997

BAR ADMISSIONS:

• District of Columbia
• Pennsylvania
• Virginia

Memberships:

• Barrister, J. Edgar Murdock Inn of Court, US Tax Court
• American Bar Association, Tax Section
• District of Columbia Bar Association, Tax Section
• Board of Directors, The Community Tax Law Project, Richmond, Virginia