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Experience:
Matthew Houchens represents taxpayers involved in contested federal tax matters during audit procedures, in the course of IRS administrative appeals, and before federal trial and appellate courts. He joined Mayer Brown in 1997.
Notable Engagements:
Wells Fargo & Company v. United States, No. 06-628 (Ct. Fed. Cl., no trial date), pending case regarding leveraged leases of transit equipment and technical equipment.
Unionbancal Corp. v. United States, No. 06-587 (Ct. Fed. Cl., no trial date), pending case regarding leveraged leases of foreign power facility and domestic sports arena.
Consolidated Edison Company of New York v. United States, No. 06-305 (Ct. Fed. Cl., tried in Oct-Nov 2007), pending case regarding leveraged lease of foreign power facility.
Tribune Company v. Commissioner of Internal Revenue, 125 T.C. 110 (2005), holding that the divestiture of Bender was a taxable sale and not a tax-free reorganization.
The Limited, Inc. v. Commissioner of Internal Revenue, 286 F.3d 324 (6th Cir. 2002), rev'g, 113 T.C. 169 (1999), reversing the Tax Court's holding that CFC's purchase of CDs from affiliated credit card bank failed to quality as §956(b)(2)(A) "deposits with [a] person carrying on banking business."
United Parcel Service of America v. Commissioner of Internal Revenue, 254 F.3d 1014 (11th Cir. 2001), rev'g and remanding, T.C. Memo. 1999-268, 78 T.C.M. (CCH) 262 (1999), vacating Tax Court's finding on sham, assignment of income and penalties.
Nestlé Holdings, Inc. v. Commissioner of Internal Revenue, 152 F.3d 83 (2d Cir. 1998), regarding Carnation acquisition, valuation of trademarks.
Education:
The John Marshall Law School, JD, summa cum laude, 1997; Managing Editor, The John Marshall Law Review, University of Illinois, BS, Engineering, 1994. | 