Kacie Dillon – Partner

Kacie Dillon represents clients in all aspects of federal and state tax controversy matters, including individual, business and gift/estate tax audits, international tax matters, captive insurance tax matters, significant collection matters and tax litigation. Mrs. Dillon is also experienced in procedural and litigation issues including discovery disputes, summons enforcement, lien and levy issues and attorney-client privilege issues.

Mrs. Dillon has notable litigation experience for various tax matters. Mrs. Dillon was lead counsel in the first litigated 831(b) captive insurance case tried in the United States Tax Court. Currently, Mrs. Dillon represents several captive insurance companies related to IRS matters including audit defense, settlement negotiations and litigation.

Mrs. Dillon is a frequent speaker at tax and captive insurance conferences, including but not limited to, ABA Tax Section, State Bar of Arizona, Captive Insurance Companies Association (CICA), Western Region Captive Insurance Conference and Delaware Captive Insurance Association.



  • Federal, State And Local Tax Litigation
  • Audit Defense
  • Captive Insurance Defense
  • Levy And Lien Relief
  • Unfiled Tax Returns
  • Penalty Relief
  • Innocent Spouse Defense
  • Offshore And Domestic Voluntary Disclosures
  • Employment Tax Matters
  • Trust Fund Recovery Penalty
  • Tax Collection Including Offers In Compromise, Installment Agreements, Currently Uncollectible/Hardship Status
  • Refund Claims


  • State Bar of Arizona
  • State Bar of Nebraska
  • United States Tax Court
  • Federal Court of Claims
  • United States District Court, District of Arizona
  • Court of Appeals, Federal Circuit


  • Oropeza v. Commissioner, 155 T.C. No. 9 (2020), (IRS failed to comply with section 6751(b) for all penalties asserted regarding captive insurance transaction, including the increased 40% penalty under section 6662(i).)
  • Oropeza v. Commissioner,C. Memo. 2020-111, (IRS failed to comply with section 6751(b) for penalty asserted regarding captive insurance transaction lacking economic substance.)
  • Panktratz v. Commissioner, Dkt. 21255-13 and 27239-13, pending decision (Charitable contribution and whether the IRS complied with section 6751(b).)
  • Wilson et al. v. Commissioner, Dkt. 26547-13, 26548-13, 15011-14, 16759-14, case settled (Third litigated 831(b) captive insurance case.)
  • Householder v. Commissioner, T.C. Memo. 2018-136 (Aug. 23, 2018). (Horse business vs. hobby.)
  • Avrahami v. Commissioner, 147 T.C. 144 (2017). (First litigated 831(b) captive insurance case.)
  • Feedback Insurance v. Commissioner, Dkt. 18274-13, Full concession of proposed tax and penalties. (831(b) captive insurance company.)
  • Cave Buttes, LLC v. Commissioner, 147 T.C. 338 (2016), decision for the taxpayer. (Charitable contribution valuation and substantial compliance with Income Tax Regulations.)


  • University of Nebraska Collect of Law, JD with Distinction
  • Nebraska Wesleyan University, Accounting B.A.


  • Premier Tax Lawyer
  • Southwest Super Lawyer
  • Southwest Super Lawyers Rising Star
  • Former Chair, State Bar of Arizona, Tax Section
  • American Bar Association, Tax Section
  • Volunteer at Low Income Tax Clinic, representing taxpayers in U.S. Tax Court