Timothy Mulvey concentrates on representing taxpayers in disputes with federal and state taxing authorities. Mr. Mulvey represents clients in all stages of tax litigation and controversies. Mr. Mulvey routinely represents clients in the US Tax Court, the US Court of Federal Claims, and US district courts when administrative resolution of a tax dispute cannot be achieved. With the goal of resolving tax disputes at the earliest possible stage, however, Mr. Mulvey works with IRS audit teams and Appeals Officers to eliminate, or at least narrow, the issues in dispute. To that end, Mr. Mulvey has successfully represented taxpayers in IRS alternative dispute resolution procedures including the Fast Track Settlement program and Post Appeals mediation. Mr. Mulvey is steadfast in seeking to reduce the audit burdens on the taxpayer and protect all applicable privileges with respect to the taxpayer's information.

Prior to joining White & Case LLP in 2003, Mr. Mulvey served as a senior attorney in the Office of Chief Counsel, Internal Revenue Service, Large and Mid-size Business Division (now known as the Large Business & International Division). In such capacity, he represented the IRS in litigation before the US Tax Court by deposing and examining witnesses, pursuing discovery and strategic motion practice, and coordinating trial and post-trial briefs. He also advised IRS examination teams during audits of multinational corporations that involved complex tax issues including subpart F income, transfer pricing, insurance charges, debt versus equity, corporate tax shelters and corporate tax shelter promoter penalties. In 2001, Mr. Mulvey received the Commissioner's Award, the highest honor the IRS chief can bestow, for his work on prosecuting corporate tax shelter and promoter penalties.

Relevant Litigation Matters

• Reorganized RFS Corp. & Subsidiaries v. United States, Fed. Cl. No. 09-371T (seeking recovery of special estimated tax payments made by a property and casualty insurer under IRC § 847);
• Clear Channel Communications, Inc. and Subsidiaries v. Comm’r, T.C. No. 004792-09 (involving the tax treatment of the taxpayer’s Shared Appreciation Income Linked Securities contracts);
• Cellco Partnership v. United States, Fed. Cl. No. 07-888T (representing a major cell phone carrier to obtain a refund of federal excise taxes imposed and paid under IRC § 4251(a));
• Rukan v. Comm’r, T.C. No. 20138-09 (involving a façade easement donation on a condominium building valued in excess of $75 million);
• Anderson v. Comm’r, T.C. No. 14866-09 (façade easement);
• Weinheim v. Comm’r, T.C. No. 14865-09 (façade easement);
• Marks v. Comm’r, T.C. No. 14860-09 (façade easement);
• Zeluck v. Comm’r, T.C. No. 10393-09 (façade easement); and
• GTE Corp. v. Comm’r, T.C. No. 13160-92 (involving the netting of interest under IRC § 6621(d)).

Bars and Courts
New York State Bar
Connecticut State Bar
US Court of Federal Claims
US District Court for the Southern District of New York
US District Court for the Eastern District of New York
US Tax Court

Education
LLM, (Taxation), New York University School of Law, 2001
JD, Brooklyn Law School, 1996
BA, State University of New York at Albany, Dean's List, 1993

Professional Associations and Memberships
Federal Bar Association (Co-Chair, New York Region, Section of Taxation, 2011 – Present)
J. Edgar Murdock Inn of Court (United States Tax Court)

Languages
English

Citizenship
United States