Thomas Johnston is a partner in the Tax practice.
He focuses on evaluating tax positions and resolving tax controversies. He also advises on a variety of substantive tax issues, particularly where a risk or hazards assessment is critical to the decision whether to proceed.
Tom has represented corporations, partnerships and individuals in a variety of state and federal tax forums. He has litigated some of the largest-dollar tax controversies for clients such as ExxonMobil, Ford Motor Co., The Hughes Companies, Sunoco Inc., and WMI Holdings Corp. (formerly Washington Mutual Inc.).
He frequently lectures on tax controversy developments and tax procedure.
- WMI Holdings in ongoing litigation involving claimed abandonment deductions for intangible assets.
- Ford Motor Co., Federal National Mortgage Association and Sunoco Inc. in a variety of interest claim litigations.
- Individuals before the IRS in connection with the voluntary disclosure of income from foreign bank accounts.
- Various corporations and partnerships at IRS Appeals in connection with proposed deficiencies relating to restructuring of domestic and foreign operations.
- Investment funds and corporations on audit and at IRS Appeals in connection with asserted withholding tax deficiencies.
University of Michigan Law School
The Wharton School at the University of Pennsylvania
- United States Court of Federal Claims
- United States Tax Court
- United States Court of Appeals (D.C., 2d, Fed. Circuit, 5th Cir.)
- Federal District Court (N.D. Tex. and W.D. Wash.)
- United States Supreme Court
Awards & Accolades
- Listed in Chambers, Legal 500 and Super Lawyers.