Mario J. Verdolini
Head of tax controversy practice. Represents clients in litigation and other tax controversies, as well as in grand jury, governmental and internal investigations.
Mario is the head of our tax controversy practice. He represents clients in litigation and other tax controversies, particularly matters involving administrative proceedings and settlements, trials, appeals and risk management. Clients also turn to Mario in connection with grand jury, governmental and internal investigations. He has represented a wide range of U.S. and international clients, including financial institutions and companies in the manufacturing, media and pharmaceutical sectors.
Many of Mario’s most successful matters have resulted in favorable settlements or complete concessions by the government and remain confidential.
Chambers USA recognizes Mario as a top tax controversy lawyer and cites clients who describe him as an “excellent tax professional who is great with controversy and litigation strategies and is able to quickly address complicated matters.”
Mario plays a lead role in our pro bono tax practice and has advised numerous exempt organizations.
Experience
Tax Litigation
- Successfully defended a global healthcare products company against a $2 billion IRS tax claim relating to a Granite Trust transaction, the first such challenge in 70 years
- Secured a complete victory on the allocation of a company’s gains associated with the sale of a subsidiary
- Obtained complete victory in U.S. Tax Court in debt/equity case for a consumer products company, after government won a string of other debt/equity cases
- Obtained complete victory in Court of Federal Claims and Court of Appeals for the Federal Circuit in tax treaty case for a U.K. bank
- Settled U.S. Tax Court case involving tax treatment of financial derivatives for media company
- Successfully representing consumer products companies in U.S. Tax Court cases involving domestic manufacturing deductions
- Successfully settled for a tax refund case in U.S. District Court involving tax treatment of corporate reorganization
Other Notable Representations
- Several clients on the potential for filing refund claims based on the Tax Court’s ruling in the Varian Medical Systems v. Commissioner case
- Several clients in connection with tax audits by the New York City Department of Finance on the allocation of corporate income to New York City
- A telecommunications company in tax sharing arbitrations
- An industrial company in connection with an SEC investigation into its accounting for taxes
- An accounting firm and its partners in providing testimony in U.S. Tax Court, U.S. District Court and Court of Federal Claims in tax credit cases
- A financial institution in connection with a grand jury investigation into tax shelters
- A national law firm in connection with a grand jury investigation relating to tax opinions
Insights
News
Recognition
Chambers USA – Tax: Controversy
ITR World Tax –Tax Controversy, New York, Highly Regarded
Lawyers Alliance for New York – Cornerstone Award, 2022
Education
- Order of the Coif
- cum laude
Qualifications and admissions
- State of New York
- U.S. Court of Appeals, Federal Circuit
- U.S. Court of Appeals, Tenth Circuit
- U.S. Court of Federal Claims
- U.S. District Court, Connecticut
- U.S. District Court, S.D. New York
- U.S. Tax Court