samuel A. mitchell

 
 
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 Expertise

Tax Controversy


Contact Information:

Phone: 202.434.9162

Email: smitchell@scribnerhall.com


Admissions:

1991

Admitted to the Bar in Colorado

1999

Admitted to the Bar in the District of Columbia

1999

U.S. Tax Court

PARTNER

 

About Sam:

Sam specializes in controversy work involving various financial product and insurance company issues representing clients before the United States Tax Court and various Federal District and Appeals Courts and in controversy work before the Appeals Division of the Internal Revenue Service. He has worked on litigation involving life insurance reserves, test cases for the health insurance and financial guaranty industries, and cases involving property-casualty tax issues. As part of his controversy practice, he has worked on a range of insurance company tax issues (both life and property-casualty) and financial product tax issues, and represented companies regarding IRS Industry Issue Resolution requests related to bad debts, variable annuity hedging and Principle Based Reserves. Sam is the update author for the LexusNexis treatise Federal Income Taxation of Life Insurance Companies (2d ed 2017). He is a frequent writer for other tax publications and a speaker at industry conferences and currently serves on the editorial board of the Society of Actuaries Taxation Section’s Taxing Times publication. Sam has been with the firm since 1999.

 

Sam's Recent Publications:

 

Sam's Speaking Engagements:

 

May 30, 2024: Insurance Tax Seminar

Topic:  Key Developments in Tax Controversy

39th Annual FBA Insurance Tax Seminar

J.W. Marriott, Washington D.C.


November 30 - December 2, 2022: Blue Cross Blue Shield National Tax Conference

Topic:  Health Insurance Litigation Update

Chicago, Illinois


June 2 - June 3, 2022: Insurance Tax Seminar

Topic:  IRS Procedure & Controversy Items

37th Annual FBA Insurance Tax Seminar

J.W. Marriott, Washington D.C.


May 30 - May 31, 2019: Insurance Tax Seminar

Topic: Investments

Washington, D.C.


May 21, 2019: Society of Actuaries Life & Annuity Symposium

Topics:  Company Taxation Update and Life & Annuity Taxation: Ask the Experts

Tampa, Florida


November 30, 2018: 2018 Blue Cross Blue Shield National Tax Conference

Topic: IRS Tax Controversy & Changes to IRS Processes

Glendale, Arizona


November 28, 2018: 2018 Blue Cross Blue Shield National Tax Conference

Topic: Investment Tax Issues

Glendale, Arizona


June 1, 2017: FBA Insurance Tax Seminar

Topic: Principle-Based Reserves

29th Annual FBA Insurance Tax Seminar

J.W. Marriott, Washington, D.C.

 

Education:

Bob Jones University - B.S. 1986 (Magna Cum Laude)

University of Denver College of Law- J.D. 1990 (Order of the St. Ives) 

Extracurricular Activities: Editor-in-Chief, Denver University Law Review

Associations:

Federal Bar Association (Tax Section)