Overview

Geoffrey Collins represents clients in all phases of tax controversy, both in court and before the Internal Revenue Service.

His experience includes major trials and Appellate cases as well as large corporate tax matters before IRS Exam and IRS Appeals. In addition, his experience includes the successful use of alternative-dispute-resolution initiatives such as the Pre-Filing Agreement program. He has represented clients in controversies involving advance pricing agreements, transfer pricing, timing of pension contribution deductions, section 199 domestic production activity deductions, carrybacks of Net Operating Losses and other tax attributes, debt-equity characterization of intercompany advances, deductibility of settlement payments under the False Claims Act, summons enforcement, and the application of economic substance, sham-transaction, and similar substance-over-form doctrines.

Geoffrey’s most recent and ongoing litigations include:

  • Eaton Corp. v. Commissioner, --- F.4th ----, No. 21-1569, 21-2674 (6th Cir. August 25, 2022) (holding that Advance Pricing Agreements were subject to ordinary contract principles and that the IRS invalidly cancelled Advance Pricing Agreements and failed to timely plead penalties);
  • Cross Refined Coal, LLC v. Commissioner, --- F.4th ----, No. 20-1015 (D.C. Cir. August 5, 2022) (holding that refined coal partnership was a bona fide partnership and affirming that, where a partnership undertakes an activity made profitable by tax credits, it engages in legitimate business activity for tax purposes);
  • GSS Holdings (Liberty) Inc. v. United States, No. 1:19-cv-00728 (Federal Circuit) (ongoing case of first impression about the limitations on the IRS’s use of the step transaction doctrine and the application of the party presentation principle); and
  • Cross Refined Coal, LLC v. Commissioner, T.C. Docket. No. 19502-17, Index No. 177 (U.S. Tax Ct. Aug. 29, 2019) (finding after trial that refined coal production partnership was a bona fide partnership and that its partners were bona fide partners).

Geoffrey received his JD magna cum laude from Cornell Law School where he was Order of the Coif and an Editor of the Cornell Law Review. Before joining Mayer Brown, he served as law clerk and attorney advisor to Hon. Richard T. Morrison of the United States Tax Court.

Areas of Focus

Practices

Spoken Languages

  • English

Experience

  • Eaton Corp. v. Commissioner, --- F.4th ----, No. 21-1569, 21-2674 (6th Cir. August 25, 2022) (holding that Advance Pricing Agreements were subject to ordinary contract principles and that the IRS invalidly cancelled Advance Pricing Agreements and failed to timely plead penalties)
  • Cross Refined Coal, LLC v. Commissioner, --- F.4th ----, No. 20-1015 (D.C. Cir. August 5, 2022) (holding that refined coal partnership was a bona fide partnership and affirming that, where a partnership undertakes an activity made profitable by tax credits, it engages in legitimate business activity for tax purposes)
  • GSS Holdings (Liberty) Inc. v. United States, No. 1:19-cv-00728 (Federal Circuit) (ongoing case of first impression about the limitations on the IRS’s use of the step transaction doctrine and the application of the party presentation principle)
  • Cross Refined Coal, LLC v. Commissioner, T.C. Docket. No. 19502-17, Index No. 177 (U.S. Tax Ct. Aug. 29, 2019) (finding that refined coal production partnership was a bona fide partnership and that its partners were bona fide partners).
  • Eaton Corporation v. Commissioner of Internal Revenue, T.C. Memo. 2017-147 (finding that the IRS’s cancellation of Advance Pricing Agreements was an abuse of discretion).
  • Guidant LLC, et. al., v. Commissioner of Internal Revenue, T.C. Docket Nos. 5989-11, 5990-11, 10985-11, 26876-11, 5501-12, 5502-12 (IRC § 482 reallocations).
  • United States v. Eaton Corporation, Nos. 1:13-mc-102, 1:13-mc-111, 1:13-mc-112 (N.D. Ohio 2014); 2:13-cv-01825 (W.D. Pa. 2014); 3:13-cv-01956 (D.P.R. 2014) (summons enforcement litigation).
  • United States v. Eaton Corporation, Nos. 1:12-mc-24, 1:12-mc-25, 1:12-mc-26, 1:12-mc-27, 2012 WL 3486910 (N.D. Ohio Aug. 15, 2012) (summons enforcement litigation).
  • Eaton Corporation v. Commissioner, T.C. Docket No. 28040-14. (Transfer pricing and sub-part F adjustments).
  • Tyco Electronics Corp., et. al v. Commissioner of Internal Revenue, T.C. Docket Nos. 16651-13, 16652-13, 16653-13, 16654-13, 16655-13, 16656-13, 16657-13, 16658-13, 16659-13, 16660-13, 16661-13, 16662-13, 16663-13, 16664-13, and 19556-13 (debt-equity characterization).
  • Keeling v. Commissioner, T.C. Docket No. 020806-11L (trust-fund recovery penalties).

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Education

Cornell Law School, JD, magna cum laude
Cornell Law Review

University of Kansas, BM, magna cum laude

Admissions

  • Illinois
  • New York