Portrait of

Government Experience

  • U.S. Department of Justice: Tax Division—Trial Attorney (1990-1995)

Education

  • Georgetown University, B.A. (1985)
  • Cornell Law School, J.D. (1989) magna cum laude, Order of the Coif

Admissions

  • District of Columbia
David B. Blair, Partner Washington, D.C.
dblair@crowell.com
Phone: +1 202.624.2765
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

David B. Blair is a partner and chair of Crowell & Moring's Tax Group. Mr. Blair's practice is in the area of federal tax litigation and controversy. With over twenty years of tax litigation and trial experience, he has handled large tax litigations in the areas of transfer pricing, foreign tax credits, partnerships, tax-exempt bonds, consolidated returns, excise taxes, employment taxes, and tax accounting issues. He is also active in pro bono litigation. Where clients sought resolution short of litigation, Mr. Blair achieved outstanding results through alternative dispute resolution procedures, including the Internal Revenue Service's (IRS) Fast Track Settlement program. He also has extensive experience in handling tax controversies before IRS Exam, Appeals, National Office, and Advance Pricing and Mutual Agreement program (APMA).

A recognized authority on tax controversy, Mr. Blair teaches transfer pricing as an adjunct professor at Georgetown University Law Center, and regularly speaks at tax conferences and symposia. He is the editor of The Transfer Pricing Answer Book (Practising Law Institute) and a co-author of the BNA Tax Management Portfolio No. 891-2nd, "Transfer Pricing: Audits, Appeals, and Penalties."

Mr. Blair began his career as a trial attorney for the Tax Division of the U.S. Department of Justice, where he litigated tax issues before the United States District and Bankruptcy Courts.

Representative Engagements

  • Exxon Corp. v. Commissioner, 113 T.C. 338 (1999) (Foreign tax credit for U.K. Petroleum Revenue Tax).
  • DeNaples v. Commissioner, 674 F.3d 172 (3d Cir. 2012) (Tax exempt interest).
  • Exxon Mobil Corp. v. Commissioner, 114 T.C. 293 (2000) (Tax accounting).
  • Mary Kay Corp. v. Commissioner, T.C. Nos. 18150-02 and 14352-03 (Transfer pricing regarding marketing intangibles).
  • Danstar Ferment, Inc. v. Commissioner, T.C. No. 12288-04 (Foreign personal holding company tax).
  • Representation of Branded Pharmaceuticals Company on International Tax Issues before IRS Exam and Appeals.
  • Representations of International Oil & Gas Companies on Partnership Issues before IRS Exam and Appeals.
  • Representation of International Oil & Gas Company on Environmental Credits before IRS Exam and Appeals.


Affiliations

Admitted to practice: District of Columbia and Massachusetts (inactive)

Court admissions:

  • United States Tax Court
  • United States Court of Federal Claims
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Eleventh Circuit
  • United States District Court for the District of Columbia
  • United States District Court for the Northern District of Texas

Memberships

  • Vice-Chair, Inter-Pacific Bar Association's Tax Committee (2015-2017)


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Firm News & Announcements

Jan.11.2016 Crowell & Moring Attorneys Named to Washingtonian's 2015 "Top Lawyers" List
Jan.13.2015 Crowell & Moring Releases Third Annual Litigation Forecast Report and Inaugural Regulatory Forecast
Jul.17.2012 Crowell & Moring Expands Tax Group with Addition of Two Tax Controversy and Litigation Partners
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