samuel A. mitchell
Expertise:
Tax Controversy
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)