Dwight Mersereau advises large multinational corporate clients in high-stakes tax policy, planning, and controversy matters. These projects involve financially significant, complex, highly technical tax issues.
Dwight represents clients involved in tax controversy with the IRS at all levels of the proceedings, including during examination, at appeals, and in litigation before the US Tax Court, US Court of Federal Claims, and US District Courts. Dwight is adept at using various settlement tools, including Fast Track settlement, Industry Issue Resolution, and alternative timing settlements. He has extensive understanding of complex tax issues gained through his more than 25 years of experience dealing with all aspects of the law, starting with his drafting of tax accounting guidance while serving in the IRS Office of Chief Counsel. The IRS chief counsel awarded Dwight the Technical Guidance Award for his publication of comprehensive guidance for accounting method changes.
Dwight has led telecommunications companies, health care companies, insurance companies, financial institutions, retailers, and trade associations through issues involving tax accounting for bonus payments; original issue discount; incentive payments; research and development expenses; capitalization and amortization of intangibles; income deferral, depreciation; the “domestic production deduction” under Section 199 of the Internal Revenue Code; and last-in, first-out (LIFO) inventory accounting.
Dwight is also involved in shaping tax policy through legislation, US 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 IRS.
- Represented a large financial institution during an IRS appeal of proposed audit adjustments of over $855 million regarding whether certain payments were capitalizable facilitative payments of an intangible asset.
- Represented a large bank during an IRS appeal of proposed audit adjustments of over $1 billion involving a variety of tax accounting issues.
- Represented a large telecommunications company during an IRS Fast Track appeal that involved whether a $100 million government incentive qualified as a non-shareholder contribution to capital.
- Represented Vesta as lead trial counsel in Vesta Corporation v. Commissioner, Nos. 26503-17 and 26847-16, a tax litigation in the U.S. Tax Court.
- Represented AT&T as lead trial counsel in AT&T Advertising, LLP v. United States, No. 16-272 T, a tax litigation in the U.S. Court of Federal Claims.
- A View from the Bench, March 4, 2026, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- IRS Appeals Update, March 4, 2026, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Recent Developments in IRS Appeals, November 13, 2025, TEI St. Louis Federal Tax Program
- Recent Developments in IRS Appeals, September 11, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Making Bad Data Pretty, June 3, 2025, TEI Region 2 Tax Forum
- Recent Developments in IRS Appeals, April 30, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Federal Tax Update, February 21, 2024, TEI Chicago Chapter’s Federal Tax Seminar
- The Future of Chevron Deference, February 21, 2024, TEI Chicago Chapter’s Federal Tax Seminar
- Mistakes Were Made: Considerations for Addressing Errors in Tax Filings, February 21, 2024, TEI Chicago Chapter’s Federal Tax Seminar
- Moore and More: Developments in Tax Controversy, November 2, 2023, Philly Tax Day
- Considerations in IRS Practice and Procedure, September 22, 2023, TEI New England
- Recent Tax Accounting Cases Answer Important Questions, October 6, 2022, Managing Tax Audits and Appeals Seminar 2022
- Specific Audit Issues: Income Tax Accounting, October 4, 2021, Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
- Tax Accounting: Basics Refresher and Recent Developments, October 6, 2020, Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2018-2025) and tax controversy (2024-2025)
- Recognized by The Legal 500 United States in the area of US taxes: contentious (2023-2025)
- District of Columbia
- U.S. Court of Federal Claims
- U.S. Tax Court
- Supreme Court of New Mexico
- LL.M. in Taxation, University of Florida Levin College of Law
- J.D., University of New Mexico School of Law
- B.S., magna cum laude, Bridgewater State University