Alex E. Sadler is a partner in the Washington, DC office's Tax Group, where he specializes in representing taxpayers in controversies with the Internal Revenue Service. Mr. Sadler has assisted taxpayers in complex tax disputes involving the research credit, tax-advantaged transactions, non-cash charitable contributions, penalties, and technical income, estate, and gift tax issues.

Mr. Sadler has extensive experience in complex tax trials, including the following cases:

• Union Carbide Corporation and Subsidiaries v. Commissioner, Docket No. 11119-99, U.S. Tax Court, November-December 2007 Special Trial Session (4-week trial).
• Union Carbide Corporation and Subsidiaries v. Commissioner, Docket No. 11119-99, U.S. Tax Court, June 2006 Special Trial Session (2-week trial).
• Dow Chemical Company and Subsidiaries v. United States, 278 F. Supp.2d 844, U.S. District Court for the Eastern District of Michigan (9-week trial).
• American Electric Power Co. v. United States, 136 F. Supp.2d 762, U.S. District Court for the Southern District of Ohio (7-week trial).
• In re C.M. Holdings, Inc., 254 B.R. 578, U.S. District Court for the District of Delaware (6-week trial)
• Keohan v. United States, 138 F. Supp.2d 62, U.S. District Court for the District of Massachusetts (multi-day trial).

Mr. Sadler handles all aspects of tax litigation, from factual development through discovery, trial, and appeal. He also helps taxpayers resolve tax issues before litigation in IRS Appeals and with issues arising during audit, such as responding to summonses, other information requests, and proposed adjustments. Mr. Sadler has spoken frequently on tax litigation, procedures for resolving tax disputes without litigation, and substantive tax issues.

Before joining Crowell & Moring, Mr. Sadler was a Trial Attorney for the U.S. Department of Justice, Tax Division, where he litigated tax cases in the federal district and bankruptcy courts. For his work representing the government in extended trials, Mr. Sadler received The Attorney General's Distinguished Service Award, as well as the Tax Division's Special Commendation for Outstanding Service. He is also recommended by the 2007 Legal 500 U.S. Litigation Book for Litigation/Tax Controversy.

Mr. Sadler received his law degree from the University of Virginia School of Law, where he served as Articles Editor for the Virginia Tax Review. Following law school, he served as a law clerk in the United States District Court for the Eastern District of Virginia.

Mr. Sadler is a member of the bars of the District of Columbia and state of Maryland, and is admitted to practice before the U.S. Tax Court, U.S. Court of Federal Claims, and numerous federal district courts.

Education
University of Virginia, B.S., 1991
University of Virginia School of Law, J.D., 1994

Affiliations
Admitted to practice: District of Columbia, Maryland, U.S. Tax Court, U.S. Court of Federal Claims

Publications
"Scope of Pretrial Discovery: A Key Difference in Litigating Tax Cases in the Tax Court and Refund Tribunals," Journal of Tax Practice & Procedure (April-May 2009). Co-Authors: Alex E. Sadler and Daniel G. Kim.

"American Recovery and Reinvestment Act of 2009," published by CCH (2009). Contributing Authors: Alex E. Sadler, Charles C. Hwang and Jennifer A. Ray.

"Emergency Economic Stabilization Act of 2008: Law, Explanation and Analysis," published by CCH (2008). Contributing Authors: Alex E. Sadler, Charles C. Hwang and Jennifer A. Ray.

"Electronic Tax Trials: Taking Advantage of the Tax Court's Electronic (North) Courtroom," Journal of Tax Practice & Procedure (August-September 2008). Co-Authors: Alex E. Sadler and Jennifer A. Ray.

"Valuation of Conservation Easements Handbook," jointly sponsored by the Appraisal Institute, American Society of Farm Managers and Rural Appraisers, American Society of Appraisers, and Land Trust Alliance (copyright 2007). Legal Consultant: Alex E. Sadler.

"Tax Advice as Work Product: The Scope of Work Product Protection in Tax Shelter Controversies," Journal of Tax Practice and Procedure, published by CCH (October/November 2004). Author: Alex E. Sadler.

"The Inherent Ambiguity of Commercial Real Estate Values," Virginia Tax Review (Spring 1994). Author: Alex E. Sadler.

Speeches & Presentations
"Economic Substance Doctrine Codified: Surviving Scrutiny Under New IRC § 7701(o)," Strafford Teleconference webinar (May 19, 2010). Moderator: Alex E. Sadler.

"Branerton and the New Tax Court E-Discovery Rules - Where Do We Go From Here?," Federal Bar Association, 34th Annual Tax Law Conference (March 2010). Speaker: Alex E. Sadler.

"Responding to IRS Information Requests," Crowell & Moring’s Coping with IRS Audits Seminar (September 2008). Speaker: Alex E. Sadler.

"Resolving Tax Issues before Litigation: PFAs, CAP, Appeals, Fast Track, Offers-In-Compromise, and Other Options for Resolving Tax Controversies," Federal Bar Association's 32nd Annual Tax Law Conference, Washington, DC (March 7, 2008). Panel moderator and speaker: Alex E. Sadler.

"From the Trenches: Insights and Practice Tips on Litigating Complex Tax Cases in the Tax Court, Court of Federal Claims, and District Courts," Federal Bar Association's 32nd Annual Tax Law Conference, Washington, DC (March 7, 2008). Panel moderator and speaker: Alex E. Sadler.

"IRS Strategies to Achieve Currency in Large Case Audits," Crowell & Moring Tax Audit Seminar, Washington, DC (October 2008). Moderator and Speaker: Alex E. Sadler.

"Defending Appraisals in IRS Audit, Appeals, and Litigation," Appraisal Institute Joint Government & Litigation Seminar, Washington, DC (September 2007). Speaker: Alex E. Sadler.

"Records Requirements and Penalties Applicable to Noncash Charitable Contributions," 2007 Tax Symposium: Matters Affecting Federal and State Tax Practice, New Mexico State Bar (June 2007). Speaker: Alex E. Sadler.

"Tax Requirements and Penalties Applicable to Appraisals Used to Substantiate Value for Non-Cash Charitable Contributions," Appraisal Institute's Spring Valuation and Litigation Services Conference - Los Angeles, CA (March 28, 2007). Presenter: Alex E. Sadler.

"Strategies to Achieve Currency in Audits and Appeals -- Challenges and Experience with Recent IRS Examination, Appeals, and Counsel Initiatives," Federal Bar Association's 31st Annual Tax Law Conference - Washington, DC (March 9, 2007). Panel Moderator: Alex E. Sadler.

"Audits, Privileges, and Tax Controversies," Crowell & Moring's Coping with IRS Audit Seminar, Washington, DC (2002-2006). Speaker: Alex E. Sadler.

"Current State of the Attorney-Client Privilege, Tax Practitioner Privilege, and Work Product Doctrine in Federal Tax Controversies," Third Annual Tax Symposium, New Mexico Bar Association (June 2005). Speaker: Alex E. Sadler.