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Robert E. Dallman

Attorney

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Robert E. Dallman

Attorney

Robert Dallman’s practice includes advising clients in complex federal and state tax audits, administrative appeals and tax litigation; tax planning; and business planning. Formerly an IRS trial attorney in Washington, D.C. and Milwaukee, he has practiced either for or against the IRS and selected state taxing authorities for more than 20 years. His experience includes the following technical tax areas:

  • IRS attacks on tax efficient domestic and international transactions
  • Valuation
  • Apportionment
  • Intangibles
  • Residency
  • Ownership succession
  • Contributions of easements
  • Executive compensation and reasonable compensation
  • Mixing bowl transactions and other partnership issues
  • Charitable contributions and estate and gift taxes
  • Transfer pricing
  • Payroll tax
  • Excise tax
  • Inventory
  • Purchase price allocations
  • REIT mirror transactions and UPREIT transactions
  • Tax accounting
  • Material distortion/clear reflection of income
  • Sham companies/sham transactions
  • Like-kind/Starker exchanges
  • Tax shelters (corporate and individual)
  • Preparer penalties and tax shelter promoter penalties
  • Passive activity losses
  • Venture capital, leveraged buyouts and debt-equity
  • Trust-preferred securities
  • Service corporations
  • Midco transactions
  • Selected insurance tax issues
  • Derivatives
  • Selected IRS attacks on offshore trusts
  • Indopco issues
  • International and domestic reorganizations and acquisitions
  • Selected state and local tax

Robert’s clients describe him as a trusted advisor and advocate who is “very strategic” and “dogged” and who “goes for the jugular when needed.” He frequently speaks to professional organizations on tax issues, and he has served as an adjunct faculty member in the University of Wisconsin-Milwaukee’s graduate tax program.

Listing of Relevant Resolved Cases

  • Georgetown University, LL.M. Taxation
  • University of Kansas, J.D.
  • Valparaiso University, B.A.

  • Wisconsin
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals, 7th Circuit
  • U.S. Supreme Court

  • Founder, Wisconsin State and Local Tax Club
  • Milwaukee Tax Club
  • State Bar of Wisconsin (Tax Section)
  • Milwaukee Bar Association (past co-chair, Tax Section)

  • Federal tax issues including debt vs. equity issues, partial worthlessness of debt, total worthlessness of debt, and whether payments made for the benefit of a third party are deductible by the payer. 
  • Litigated numerous tax cases to completion as the lead or sole tax attorney and actively managing multiple cases regarding federal tax issues including debt vs. equity issues, partial worthlessness of debt, total worthlessness of debt, and whether payments made for the benefit of a third party are deductible by the payer. 
  • Litigated significant cases in the areas of partnership taxation, valuation, gift tax, estate tax, the taxation of inventories, sham transactions and the income tax aspects of real estate transactions including like-kind/tax-deferred exchanges. 
  • Litigated landmark cases in the area of executive/reasonable compensation, Code Section 2703(b) and officer liability.

  • The Best Lawyers in America®, Litigation & Controversy-Tax (2011-2023), Taw Law (2003-2023)
  • Wisconsin Super Lawyers® (2005-2021)

Areas of Practice

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Robert E. Dallman
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