Education

  • Bridgewater State University, B.S. (1987) magna cum laude
  • University of New Mexico School of Law, J.D. (1990)
  • University of Florida Levin College of Law, LL.M. Taxation (1995)

Admissions

  • District of Columbia

Dwight N. Mersereau

Partner
dmersereau@crowell.com
+1.202.624.2856

Dwight Mersereau is a Tax Group partner in Crowell & Moring's Washington, D.C. office. Dwight represents large, multinational corporate clients in high-stakes policy, planning, and controversy matters. These projects typically involve complex, highly technical tax accounting issues involving billions of dollars. Dwight is involved in shaping tax policy through legislation, U.S. Department of the Treasury regulation projects, revenue rulings, and private letter rulings. He has represented individual clients, industry associations, and client coalitions before Congress, the Treasury, and the Internal Revenue Service (IRS). Over the years, Dwight has fostered close working relationships with officials at the IRS and Treasury. He has frequently provided comments to policy makers grappling with difficult tax accounting issues.

Dwight also represents clients involved in controversy with the IRS at all levels of the proceedings, including during examination, at appeals, and in litigation before the U.S. Tax Court. He achieves impressive results for his clients because of his depth of understanding of complex tax accounting issues gained through his more than 25 years of experience in dealing with all aspects of the law, which he first obtained in drafting tax accounting guidance while serving in the Office of Chief Counsel.

Recent cases have involved leading manufacturers, financial institutions, retailers, and construction companies, and included issues involving accounting for credit card fees; original issue discount; accounting for research and development expenses; capitalization and amortization of intangibles; last-in, first-out (LIFO) inventory accounting; income deferral; uniform capitalization costs of inventory and self-constructed assets; the “production deduction” under Section 199 of the Internal Revenue Code; the percentage-of-completion method; and depreciation. Dwight is adept at using various settlement tools, including Fast Track settlement, Industry Issue Resolution (IIR), and alternative timing settlements.

Dwight has been named a recognized practitioner in the tax field by Chambers USA.

Dwight began his career as an appellate and trial lawyer in the Office of the Judge Advocate General in the United States Navy. In addition to briefing dozens of cases, he has orally argued 10 cases before the U.S. Court of Appeals for the Armed Forces and the Navy-Marine Corps Court of Military Review. Dwight rose to head trial counsel at the Charleston Naval Base and was the lead prosecutor in more than 50 felony cases.

While in the IRS Office of Chief Counsel, in the Office of the Associate Chief Counsel (Income Tax & Accounting), the chief counsel awarded Dwight the Technical Guidance Award for his publication of comprehensive guidance for accounting method changes.

Dwight is a frequent writer and lecturer on tax accounting issues. From 2003 to 2005, he was an adjunct professor of law at the Georgetown University Law Center, where he taught Income Tax Accounting in the Masters of Law Program.


Affiliations

Admitted to practice: District of Columbia, New Mexico (inactive), U.S. Court of Claims, U.S. Tax Court, Supreme Court of New Mexico



Insights

Speeches & Presentations


Publications

  • "Tax – Got Tax Questions? Be a Squeaky Wheel," Crowell & Moring's Regulatory Forecast 2019 (February 27, 2019). Contributors: Dwight N. Mersereau and Charles C. Hwang.
  • "Accounting For Partnership Changes In Accounting Methods," Tax Analysts (June 13, 2018). Authors: Jennifer A. Ray, and Dwight N. Mersereau.
  • "Tax – What Congress Giveth, the IRS Taketh Away," Crowell & Moring's Litigation Forecast 2018 (January 2018). Contributor: Dwight Mersereau.
  • "New IRS Regulations Affect Brewers," The New Brewer (July – August 2014). Author: Dwight N. Mersereau.
  • "IRS Addresses Whether Publisher Is 'Producer' Under §199," Bloomberg BNA (April 2013). Author: Dwight N. Mersereau.
  • "The New Repair Regulations - Some Things to Consider," The Tax Executive (March - April 2012). Author: Dwight N. Mersereau.
  • "Navigating the Accounting Method Change Landscape - The New §381 Regulations and Other Developments," Tax Management Memorandum (December 19, 2011). Author: Dwight N. Mersereau.
  • "IRS Audits of Gift Card Sales: Practical Tips and Strategies," Tax Management Memorandum (December 21, 2009). Author: Dwight N. Mersereau.
  • "Changing Times: IRS Updates 'Automatic' Method Change Program," The Tax Executive (January – February 2009). Author: Dwight N. Mersereau.
  • "The IRS Takes Aim at Gift Card Sales," Tax Notes (September 10, 2007). Author: Dwight N. Mersereau.
  • "Chief Counsel Revamps Case-Specific Advice Procedures to Match LMSB's New Enforcement Paradigms," The Tax Executive (July - August 2006). Author: Dwight N. Mersereau.
  • "So Much for Simplification - IRS Discourages Taxpayers From Using the IPIC Pooling Method," Journal of Taxation (March 2006). Author: Dwight N. Mersereau.
  • "IRS Further Expands Capitalization Requirement for Environmental Cleanup Costs," BNA Daily Report for Executives (November 2005). Author: Dwight N. Mersereau.
  • "Whatever, Whenever: Treasury Further Expands Capitalization Requirement of Environmental Cleanup," Tax Management Weekly Report (October 17, 2005). Author: Dwight N. Mersereau.

Client Alerts & Newsletters


Firm News & Announcements

May 20, 2021 Chambers USA 2021 Ranks 63 Crowell & Moring Lawyers and 30 Practice Areas Among Best in U.S.
February 17, 2020 Crowell & Moring’s Tax Group Recognized by World Tax and World Transfer Pricing
April 29, 2019 Chambers USA 2019 Ranks 53 Crowell & Moring Lawyers and 21 Practice Areas Among Best in U.S.
May 9, 2018 Chambers USA 2018 Ranks 52 Crowell & Moring Lawyers and 24 Practice Areas Among Best in U.S.
October 6, 2015 Crowell & Moring Bolsters Tax Group with Partner Dwight N. Mersereau