Alex E. Sadler specializes in representing taxpayers in tax litigation and administrative controversies with the Internal Revenue Service, U.S. Department of Justice, and state tax authorities. Based on client input, Alex was ranked in Chambers USA 2010 and Chambers USA 2011 as a leading lawyer in his field.

Alex has a particular expertise with the "Credit for Increasing Research Activities" under section 41 of the Internal Revenue Code, commonly referred to as the research credit, R&D tax credit, and R&E tax credit. The research credit is a valuable tax incentive created by Congress to encourage U.S. businesses to increase their R&D activities and spending. Alex is the co-author of "Navigating the Research Credit," Tax Notes, 132TN1253 (Sept. 19, 2011).

Representative R&D tax credit matters include:

• Representing an environmental consulting firm in an administrative appeal over the R&D tax credit
• Representing a multinational sciences company in litigation over the R&D tax credit
• Represented a global petrochemical manufacturer in Tax Court litigation over the R&D tax credit
• Representing a global petroleum refining and chemicals company in an audit and appeal of R&D tax credit issues
• Represented a large aerospace parts manufacturer in an audit and appeal of R&D tax credit issues
• Represented a large retail service company in defense of R&D tax credit claims for internal use software development
• Represented pesticide research partnerships in administrative appeals involving R&D tax credit issues

Alex is an experienced tax litigator. As a Trial Attorney with the Department of Justice's Tax Division, he was awarded The Attorney General's Distinguished Service Award and the Tax Division's Outstanding Attorney Award for his representation of the federal government in three extended trials involving broad-based, leveraged corporate-owned life insurance (COLI) programs, which the IRS attacked as abusive tax shelters. In both government service and private practice, Alex has significant tax litigation experience.

Alex is also experienced in resolving tax controversies before litigation. He has helped many taxpayers negotiate favorable settlements with the IRS Appeals Office. He has also worked with many taxpayers before and during audit to protect their tax positions.

• Union Carbide Corp. and Subs. v. Commissioner, 97 T.C.M. (CCH) 1207 (U.S. Tax Ct.) (5-week and 2-week trials)
• CSX Corp. & Subs. v. IRS, Case No. 1:08-cv-01901 (HHK) (D.D.C.)
• Marriott Int'l Resorts v. United States, 437 F.3d 1302 (Fed. Cir. 2006)
• Sodexho, Inc. and Subs. v. United States, Case No. 8:06-cv-01885-AW (D. Md.)
• Doe v. Wachovia Corp., 268 F. Supp. 2d 627 (W.D.N.C. 2003)
• Estate of Clare C. Jones v. Commissioner, Case Nos. 15901-02 & 15902-02 (U.S. Tax Ct.)
• Sodexho, Inc. v. Commissioner, Case No. 11121-01 (U.S. Tax Ct.)
• The Dow Chemical Co. and Subs. v. United States, 278 F. Supp. 2d 844 (E.D. Mich. 2003) (9-week trial)
• American Electric Power Co. v. United States, 326 F.3d 737 (6th Cir. 2003)
• American Electric Power Co. v. United States, 136 F. Supp. 2d 762 (S.D. Ohio 2001) (7-week trial)
• American Electric Power Co. v. United States, 191 F.R.D. 132 (S.D. Ohio 1999)
• In re CM Holdings, Inc., 301 F.3d 96 (3d Cir. 2002)
• In re CM Holdings, Inc., 254 B.R. 578 (D. Del. 2000) (6-week trial)
• Keohan v. United States, 138 F. Supp. 2d 62 (D. Mass. 2001) (multiday trial).
• Andrews v. United States, 69 F. Supp. 2d 972 (N.D. Ohio 1999)
• Murphy v. United States, 83 A.F.T.R.2d 99-1167 (D. Me. 1999)
• Tornichio v. United States, 81 A.F.T.R.2d 98-1377 (N.D. Ohio 1998)

• "Jurisdiction Issues in Courts with Federal Tax Liability Matters," Federal Bar Association, 36th Annual Tax Law Conference, Washington, DC (March 2, 2012). Panelist/Presenter: Alex E. Sadler.
• "Litigating R&D Cases -- Insights, Strategies, and Traps for the Unwary," ABA Tax Section 2012 Midyear Meeting, San Diego, CA (February 17, 2012). Moderator: Alex E. Sadler.
• "Requests for Admission in Federal Tax Litigation: Uses, Best Practices, and Traps for the Unwary," American Bar Association Section of Taxation, 2011 Joint Fall CLE Meeting, Court Practice and Procedure Roundtable (October 21, 2011). Speaker: Alex E. Sadler.
• "Establishing and Defending the Research Credit," Tax Executives Institute, Cincinnati Chapter Meeting, Columbus, Ohio (Sept. 19, 2011). Speaker: Alex E. Sadler.
• "Strategies for Audits and Appeals," Tax Executives Institute, Cincinnati Chapter Meeting, Columbus, Ohio (Sept. 19, 2011). Speaker: Alex E. Sadler.
• "Economic Substance Doctrine Codification: Analysis of New Section 7701(o) and Implications for Tax Practitioners," Federal Bar Association, 35th Annual Tax Law Conference (Feb. 2011). Moderator: Alex E. Sadler.
• "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.
• "Research Credit Litigation: Analysis and Implications," Tax Executives Institute, Houston Chapter Meeting (May 21, 2009). Speaker: Alex E. Sadler.
• "Responding to IRS Information Requests," Crowell & Moring’s Coping with IRS Audits Seminar (September 2008). 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.
• "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
• "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.