samuel A. mitchell



Tax Controversy

Contact Information:

Phone: 202.434.9162




Admitted to the Bar in Colorado


Admitted to the Bar in the District of Columbia


U.S. Tax Court



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-May 31, 2019: FBA 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

Federal Bar Association 29th Annual Insurance Tax Seminar

JW Marriott, Washington, D.C.



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


Federal Bar Association (Tax Section)