Gregory S. Lynam
Washington, District of Columbia
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Mr. Lynam practices primarily in the area of tax whistleblower claims and federal tax controversies. Prior to joining The Ferraro Law Firm, Mr. Lynam was Counsel at Miller & Chevalier Chartered, in
Washington, D.C., and was an Associate with Baker & Mckenzie LLP in the Chicago and
San Diego offices. Both firms' tax controversy groups are ranked as one of the top five tax litigation practices in the
United States by Chambers & Partners USA. Mr. Lynam
practiced in the areas of federal tax controversy and tax appeals, with a focus on international tax matters. He has represented multi-national corporations and high-net-worth individuals at all levels of a tax controversy before the Internal Revenue Service and in litigation with matters often involving deficiencies and refunds in the hundreds of millions to billions of dollars. Mr. Lynam has specialized in controversies involving partnership issues, transfer pricing, interest allocation, R&E credit, and tax-advantaged transactions.
Mr. Lynam's practice before the Internal Revenue Service includes making submissions to the IRS Whistleblower Office, litigating IRS Whistleblower Office award determinations before the U.S. Tax Court, and also handling tax disputes from the audit level through litigation and appellate review, including IRS Appeals, Competent Authority and alternative dispute resolution procedures such as the Pre-filing Agreement and Advanced Pricing Agreement programs. He also regularly counsels taxpayers on steps to be taken before controversies with the Internal Revenue Service arise and strategic considerations with respect to filing claims for refund. Mr. Lynam's pro bono practice has focused primarily on criminal defense including a grant of clemency in a post-conviction death penalty case and a not-guilty verdict in a juvenile murder trial. He has won numerous awards for his pro bono work.
Mr. Lynam is a 2006-2007 John S. Nolan Fellow, awarded by the American Bar Association Section of Taxation.
He speaks frequently at the American Bar Association and Tax Executives Institute (TEI) on TEFRA partnership litigation, managing tax controversies, and new technologies in the courtroom. He is the current chair of the TEFRA subcommittee of the ABA Section of Taxation, Court Procedure & Practice committee and the immediate past chair of the Technology in the Courtroom subcommittee.
In addition to non-docketed matters, Mr. Lynam's work on docketed tax cases include:
Exxon Mobil Corp. v. Commissioner , U.S. Tax Court No. 11805-00 (multiple issues including fair market value interest allocation and treatment of pre-judgment interest).
Washington Mutual, Inc. v. United States
, U.S. District Court for the Western District of
Washington No. CV 06-1550 JCC (abandonment loss for branching rights acquired in a supervisory thrift merger).
Capital One Financial Corp. v. Commissioner , U.S. Tax Court Nos. 19519-05 & 24260-05 (treatment of interchange fees as OID).
Black & Decker Corp. v. United States
,
U.S. District Court for the District of Maryland No. WDQ-02-2070, on remand from 436 F.3d 431 (4th Cir. 2006) (capital loss from the sale of stock in contingent liability healthcare subsidiary).
Barrick Resources (USA) Inc. v. United States , 99 A.F.T.R.2d (RIA) 307 (D. Utah 2006) (proper period of limitations and related claims for refund).
Veritas Software Corp. v. Commissioner , U.S. Tax Court No. 12075-06 (multiple transfer pricing issues including cost-sharing buy-in payment).
John Doe 1 and John Doe 2 v. United States , 398 F.3d 686 (5th Cir. 2005), rev'g 93 A.F.T.R.2d (RIA) 1808 (holding that period of limitations under IRC section 6501 is not subject to equitable tolling).
United States v. Sidley Austin Brown & Wood, LLP , (motion to intervene on behalf of Baker Doe 1 and Baker Doe 2), U.S. District Court for the Northern District of Illinois No. 03-9355 (application of attorney-client privilege to protect from compelled disclosure the identities of taxpayers).
United States v. KPMG, LLP , (motion to intervene on behalf of John Doe 1 and John Doe 2), U.S. District Court for the District of Columbia No. 02-295 (application of IRC section 7525 to protect from compelled disclosure the identities of taxpayers).
Jefferson Smurfit Corp. v. United States , U.S. District Court for the Eastern District of Missouri No. 4:03 CV 01691 (E.D. MO 2005), rev'd 439 F.3d 448 (8th Cir. 2005) (application of res judicata to tentative refunds).
Bravo Restaurants Inc .v. United States , U.S. District Court for the Northern District of Illinois No. 04cv07117 (N.D. Ill. 2005) (collection due process issues).
Aeroquip-Vickers, Inc. v. Commissioner , 347 F.3d 173 (6th Cir. 2003), cert denied 543 U.S. 809 (2004) (applicability of investment tax credit).
Baskes v. Commissioner , U.S. Tax Court No. 40543-86 (multiple individual tax issues).
Framatome Connectors USA, Inc. v. Commissioner , 94 A.F.T.R.2d (RIA) 5820 (2nd Cir. 2004) (status of subsidiary as controlled foreign corporation).
Microsoft Corp. v. Commissioner , 311 F.3d 1178 (9th Cir. 2002) (transfer pricing issues).
Compaq Computer Corp. v. Commissioner, 277 F.3d 278 (5th Cir. 2001) (transfer pricing issues).
- U.S. Supreme Court
- U.S. District Court Northern District of Illinois Trial Bar
- U.S. Tax Court
- U.S. Court of Appeals District of Columbia Circuit
- U.S. Court of Appeals 5th Circuit
- U.S. Court of Appeals 7th Circuit
- U.S. Court of Appeals 8th Circuit
- California
- Illinois
- New York University School of Law, New York, New York,
2001
LL.M. - Taxation Specialty
- University of Iowa College of Law, Iowa City, Iowa,
2000
J.D.
Honors: With Distinction
- Iowa State University, Ames, Iowa,
1996
B.S.
- American Bar Association
- Member - Tax Section
- ABA Section of Taxation, Court Procedure & Practice committee - TEFRA subcommittee
- Current Chair
- ABA Section of Taxation, Court Procedure & Practice committee - Technology in the Courtroom subcommittee
- Immediate Past Chair
- Illinois Bar Association
- Member
- Chicago Bar Association
- Member
- National Association of Criminal Defense Lawyers
- Member
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