Kevin Spencer
Kevin Spencer
Biography
Kevin is the head of the Tax Controversy practice, and advises on complex tax matters on behalf of businesses, tax-exempt entities, and high-net worth individuals. He has substantial experience assisting clients resolve disputes with the Internal Revenue Service (IRS) at the IRS Appeals and Examination/Audit divisions, competent authority, and litigates tax disputes in federal court (US Tax Court, US District Court, US Court of Federal Claims, and US Circuit Courts of Appeals).
In addition to his tax controversy practice, Kevin advises clients on various tax issues, including tax accounting, civil and criminal tax penalties, IRS procedures, reportable transactions, and tax shelters.
After earning his Master of Laws in Taxation (LL.M.) degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court.
Kevin is a prolific writer and lecturer on a variety of tax law topics.
Prior to joining White & Case, Kevin was a tax controversy partner practice at another international law firm.
Experience
Representative litigation matters include the following:
Fiona McMillan v. Commissioner (Tax Court Docket No. 13876-23)
Prem and Venkamma Reddy v. Commissioner (Tax Court Docket No. 26415-22)
Henry and Susan Samueli v. Commissioner (Tax Court Docket No. 25811-22)
Valerie Lindsey v. Commissioner (Tax Court Docket No. 23432-22)
Estate of Stanley F. Fulton v. Commissioner (Tax Court Docket No. 7200-22)
Apache Corp. and Subs. v. Commissioner (Tax Court Docket No. 25984-22)
John M. Tocco v. Commissioner (Tax Court Docket No. 12520-22)
Growmark, Inc. v. Commissioner (Tax Court Docket No. 9076-17)
Growmark, Inc. v. Commissioner (Tax Court Docket No. 23797-14)
Ag Processing, Inc. Commissioner (Tax Court Docket No. 23479-14)
Print Media LLC, Cerberus YP LLC, Tax Matters Partner v. Commissioner (Tax Court Docket No. 2716-21)
Lisa Mather v. Commissioner (Tax Court Docket No. 14444-21)
Prime Healthcare Services – Montclair LLC v. Commissioner (Tax Court Docket No. 6721-19 (2019))
Illinois Tool Works, Inc. v. Commissioner (T.C. Memo. 2018-121)
Carlos O. Vargas v. Commissioner (Tax Court Docket No. 4793-18L)
YP LLC v. Commissioner (Tax Court Docket Nos. 34101-18, 23295-18, 23101-18, 245-19)
PDV Holding, Inc. v. Commissioner (Tax Court Docket No. 22643-18)
Uxbridge Solar LLC v. United States, 1:17-cv-00695-CFL (Fed. Cl.)
CTC MA I, LLC v. United States, 1:17-cv-00498-LKG (Fed. Cl.)
Kleen Tech Solutions, LLC v. United States, 1:17-cv-00999-SGB (Fed. Cl.)
DiMare, Inc. v. Commissioner (Tax Court Docket No. 24396-13)
John Hancock Life Ins. Co. v. Commissioner and Manufacturers Investment Corp. v. Commissioner, 141 T.C. No. 1 (2013)
Mohammad A. Kakeh & Toni L. Kakeh v. Commissioner (Tax Court Docket No. 10728)
Goodrich Corp. v. United States, 2012 US Dist. LEXIS 5301 (W.D.N.C. Jan. 18, 2012) and Goodrich Corp. v. Commissioner, No. 29180-09 (Tax Ct. filed December 8, 2009)
Capital One Fin. Corp. v. Commissioner, 659 F.3d 316 (4th Cir. 2011), aff'g 130 T.C. 147 (2008) and 133 T.C. 136 (2009)
James Allen Barksdale v. Commissioner (Tax Court Docket No. 17696-08)
Dragon Coeur LLC I-D Partnership; Edward H. Arnold, Tax Matters Partner v. Commissioner (Tax Court Docket No. 11305-07)
*All matters prior to joining White & Case.
2002
1996
1992
"High Wealth Audits – The Greatest Hits (SECA, Aircraft)", Tax Controversy Forum | NYU SPS, June 2026: New York, NY
"International Tax Disputes: How to prepare for an ever-evolving global stance," September 2025: ITR, Amsterdam, NL
"In-House Tax Practice – A Private Company Perspective," May 2025: TEI, New York.
"Federal Tax Controversy – Updates, Responding to IDRs, and Protests," May 2025: TEI, Carolinas.
"How to Win Valuation Cases Before the IRS and U.S. Tax Court," March 2025: ALI, Washington, DC.
Recent publications include:
Reporting Prediction Market Wins A Safe Bet Amid IRS Silence, Law 360 Tax Authority, August 25, 2026
Chambers Global Practice Guides, Transfer Pricing, 2026
Tax disputes with the IRS need more ADR for better administration, White & Case LLP, Tax Notes, 17 December 2025 (co-authors, T. Markus Funk and Sean Lyons)
Partnership tax audits for dummies, White & Case, November 2025
Tax treaty allows discovery of phone records, White & Case, September 2025
Goodbye to the IRS AOF Information Document Request, White & Case, July 2025
The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers, White & Case, June 2025
Chambers Global Practice Guides, Tax Law and Practice—USA, 2025
