Bill Lee's 30 years of tax controversy experience includes the representation of individuals, trusts, estates, partnerships, corporations, and other entities in IRS examinations, Appeals Office proceedings, and in litigation. Bill strives to resolve tax controversies successfully as efficiently as possible for the client (i.e., at the lowest level possible), but has also litigated cases in U.S. Tax Court, the Court of Federal Claims, and U.S. District Courts around the country.

Bill began his professional career in the Tax Department of a "Big Eight" accounting firm and is a certified public accountant. Bill has been a partner in the Tax Department of Fulbright & Jaworski L.L.P. since 1985.

• Over 30 years of trial court experience in U.S. Tax Court, U.S. District Courts, and the Court of Federal Claims
• Appellate court experience in Circuit Courts of Appeals and the Federal Circuit
• IRS examinations
• Resolution of docketed and nondocketed cases in the IRS Appeals Office
• Disputes regarding tax sharing agreements
• Electronic discovery
• Certified public accountant, three years "Big 8" accounting firm experience 

Litigation

• Public pharmaceutical company in U.S. District Court suit for refund of over $470 million regarding derivative financial instruments, international tax issues, and issues relating to the economic substance, substance over form, and step transaction doctrines
• Public integrated oil and gas company in U.S. Tax Court case and related appeal to the Fifth Circuit regarding cost allocation and taxable income issues
• Public consumer products company in U.S. Tax Court case involving transfer pricing, the application and interpretation of Treasury regulations, and possessions tax credit issues
• Public utility in U.S. Tax Court case involving the proper tax treatment of line pack gas and cushion gas, and change of accounting method issue
• Public energy company in U.S. District Court case and related appeal to the Seventh Circuit regarding the taxpayer's intervention in a summons enforcement action for accounting firm workpapers and claims of tax practitioner privilege and work product protection
• Public oil and gas exploration and production company in Court of Federal Claims suit for refund and related appeal to the Federal Circuit regarding the allocation of interest expense
• Public waste disposal company in U.S. Tax Court case regarding the existence, valuation, and amortization of intangible assets
• Individual taxpayer in U.S. Tax Court case regarding income tax issues relating to her expatriation and adoption of Austrian citizenship
• Public oil and gas companies in Harris County, Texas District Court case regarding issues relating to the Tax Sharing Agreement the companies had entered into with their former parent corporation, a public railroad company, before the spin off of the oil and gas subsidiaries
• Public oil and gas company in Harris County, Texas District Court case regarding issues relating to the Tax Sharing Agreement for a pipeline project joint venture

Appeals Office – Docketed Cases Settled

• Individual and corporate taxpayers in related U.S. Tax Court cases regarding the proposed characterization of a transaction as a taxable sale under the step transaction doctrine vs. qualification as a tax free reorganization
• Public company in a U.S. Tax Court case regarding depletion, insurance, and statute of limitations issues
• Public company in a U.S. District Court suit for refund regarding cost allocation and statute of limitations issues
• Public company in a U.S. Tax Court case involving issues relating to oil and gas production payments
• Estate in a U.S. Tax Court case regarding the valuation of real estate and the stock of a closely held corporation

Appeals Office – Nondocketed Cases

• Public company regarding transfer pricing issues
• Public company regarding transfer pricing (cost sharing) and research credit issues
• Public company regarding income tax issues relating to a cross-border financing transaction
• Public company regarding various income tax issues including proposed deficiencies relating to advances from foreign affiliates
• Public company regarding worthless stock deduction
• Public company regarding proposed disallowance of loss on the disposition of operations
• Public company regarding the proper income tax treatment of the disposition of oil and gas properties
• Public company regarding overpayments of interest and statute of limitations issues
• Public company regarding the valuation and amortization of intangible assets and covenants not to compete
• Public company regarding investment tax credit issues relating to the qualification of progress expenditures for a manufacturing plant
• Public company regarding income and employment tax issues relating to product evaluation and employee lease programs
• Corporate taxpayer regarding inventory issues
• Corporate taxpayer regarding allocation of purchase price issues and related depreciation and depletion issues
• TEFRA partnership regarding numerous income tax issues relating to when an energy plant was placed in service and when the plant was disposed of by the partnership
• TEFRA partnership regarding income tax issues relating to the taxability of sports stadium seat license sales proceeds and the existence, valuation, and amortization of intangible assets
• Health care organization regarding its continued qualification for exempt status following the formation of a joint venture with a for-profit health care company
• Corporate and individual taxpayers regarding valuation issues in connection with a taxable spin off of business operations
• Members of a nonprofit organization regarding the taxability of marketing incentive payments and cost rebates received by the members from the organization
• Oil and gas exploration and production companies regarding expense allocation and taxable income issues
• Corporate taxpayer regarding accumulated earnings tax issues
• Estate regarding refund of estate taxes relating to interest expense and other deductions incurred by the estate
• Trusts regarding the valuation of assets received in the redemption of stock held by the trusts
• Trust regarding the proposed classification of losses as passive activity losses
• Individual taxpayer regarding various income tax issues including depletion, depreciation, investment credit recapture, and constructive receipt
• Individual taxpayer regarding whether his loss of United States citizenship had as one of its principal purposes the avoidance of United States taxes

IRS Examinations

• Team leader in the successful representation of a public company subject to a civil tax fraud examination as a result of a tax whistleblower's allegations
• Team leader in the successful representation of a public company regarding income tax and penalty issues related to allegations of FCPA violations
• Head of a team representing over one hundred high net worth individuals around the country regarding listed transactions involving derivative financial instruments and foreign currency transactions and economic substance, penalty, and procedural issues including interest suspension
• Public companies in responding to administrative summonses, including those requiring the review of voluminous electronic documents and the defense of claims of attorney-client and tax practitioner privilege and work product protection
• Public companies regarding tax and penalty issues relating to backdated stock options
• Public company regarding gains and losses on hedging transactions involving derivative financial instruments
• Public companies regarding income and employment tax issues relating to employee discounts and other fringe benefits
• Public company regarding losses on stock sales
• Corporate taxpayers regarding accumulated earnings tax examinations
• Corporate taxpayer regarding income and excise tax issues
• TEFRA partnership regarding various issues relating to intangible assets, amortization deductions, and the entity which was the true earner of income
• Individual taxpayers regarding various income tax and penalty issues
• Estate in an examination involving the valuation of art, real estate, and numerous other assets
• Estate in an examination involving the valuation of real estate
• Estate in an examination involving the proposed inclusion of life insurance proceeds in the taxable estate

• American Bar Association, Section of Taxation, Committee on Court Procedure
• State Bar of Texas, Section of Taxation
• Houston Bar Association, Section of Taxation
• National Institute for Trial Advocacy week-long “Litigating Before the United States Tax Court” program, faculty member

• “America’s Leading Lawyers for Business," Chambers USA (2005 - 2010)
•  Best Lawyers in America 
• “AV” rated by Martindale – Hubbell

• Co-author, "IRS About To Start Detailed Employment Tax Examinations," Fulbright & Jaworski L.L.P. Briefing
• Co-author, "IRS Announces New Broad Disclosure Requirements for Uncertain Tax Positions," Fulbright & Jaworski L.L.P. Briefing
• Co-author, "Recent Taxpayer Economic Substance Victories Provide Blueprint for Success," BNA Daily Tax Report, December 10, 2009 
• Co-author, "IRS Takes Aim at Offshore Services to the Oil & Gas Industry," Fulbright & Jaworski L.L.P. Briefing
• Co-author, "IRS Targets Employment Taxes To Close Tax Gap," Fulbright & Jaworski L.L.P. Briefing
• Co-author, "Newly Minted 'For Use in Possible Litigation' Test of Textron May Have Far-Reaching Implications for Taxpayers," BNA Daily Tax Report, August 28, 2009 

Bill has spoken to such audiences as the Tax Executives Institute, American Bar Association, Texas State Bar Association, and Houston Bar Association Tax Sections, the American Petroleum Institute Tax Conference, The University of Texas School of Law Oil and Gas Tax Conference, the University of Virginia Conference on Federal Taxation, and the Advanced Federal Tax Litigation Conference sponsored by the SMU School of Law. Topics addressed in Bill's recent speeches relating to tax controversy matters include developments in the attorney-client privilege, work product doctrine, and tax practitioner privilege, procedures relating to electronic discovery, tax controversies involving a TEFRA partnership, recent developments in IRS examination and government tax litigation procedures, and recent developments in transfer pricing matters.  Bill was a faculty member at the National Institute of Trial Advocacy week-long program “Litigating Before the United States Tax Court.”

1979 - L.L.M., Taxation, New York University School of Law
1975 - LL.B., University of Texas School of Law
1972 - B.B.A., Accounting and Finance, University of Texas

Bill is admitted to practice before the U.S. Court of Appeals for the Fifth Circuit, U.S. District Court for the Southern District of Texas, United States Tax Court, the United States Court of Federal Claims, and the Federal Circuit.