Experience 

Nicole Reuling represents clients in administrative proceedings and litigation in complex tax matters. Before joining Mayer Brown, Nicole practiced as a trial attorney with the Tax Division, US Department of Justice. She played a prominent role in two of the Tax Division’s most notable cases in recent years: Long-Term Capital Holdings v. United States and Dow Chemical Co. & Subsidiaries v. United States . In addition, she was involved in multiple trials and in numerous cases that were resolved on dispositive motions or through settlement. Nicole received two Special Commendation awards during her tenure at the Tax Division.

At Mayer Brown, Nicole focuses on controversies associated with complex tax matters, many of which have the potential to be litigated. She also represents third parties in responding to subpoenas issued by the Department of Justice, Tax Division. Nicole was recently involved in the trial of Consolidated Edison Co. of New York v. United States, conducted in the Court of Federal Claims.

Nicole began her practice with Mayer Brown in 2005, after serving with the DOJ’s Tax Division from 2000 to 2004.

Notable Engagements 

• Brunswick Corporation & Subsidiaries v. United States of America, U.S. District Court, Northern District of Illinois, Docket No. 07C 3792, (basis for depreciation in an I.R.C. §338 acquisition transaction).
• Consolidated Edison Co. of NY v. United States, Case No. 06-305 (Ct. Fed. Claims). Representing plaintiff in litigation regarding tax treatment of leasing transaction; pending.
• Long-Term Capital v. United States, Case No. 3:01-1290 (USDC D. Conn.). Represented the United States in litigation regarding tax treatment of investment transaction and penalties assessed by the Internal Revenue Service.
• Dow Chemical Co. & Subsidiaries v. United States, Case No. 00-10331 (USDC E.D. Mich.). Represented the United States in litigation regarding tax treatment of corporate-owned life insurance policies.

Education 

Harvard Law School, JD, 2000 • Albion College, BA, summa cum laude, 1997; Phi Beta Kappa

Admitted

• Court of Federal Claims, 2006
• District of Columbia, 2004
• Tax Court, 2004
• Illinois, 2000