Overview


Roy E. Crawford focuses his practice on corporate franchise and income taxation, personal income taxation, and sales and use taxation. He represents taxpayers in disputes and tax planning in many jurisdictions, with an emphasis in states that have adopted the Uniform Division of Income for Tax Purposes Act.

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Results


  • Received determination from FTB that liquidation of an insolvent subsidiary resulted in treatment of intercompany debt as a deemed contribution to capital, resulting in recognition of a multibillion-dollar worthless stock deduction
  • Resolved a dispute in which the FTB regarded the C election by a federal S corporation as an abusive tax avoidance transaction
  • Resolved a dispute in which the FTB regarded the combination of a homebuilding enterprise with a mortgage company as resulting in factor distortion

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Recognitions


  • The Best Lawyers in America 1987 to 2020, Litigation and Controversy – Tax, Tax Law
  • World Tax, International Tax Review 2016, 2017
  • California State Bar Association, Taxation Section, 2012 Benjamin F. Miller Award for outstanding achievement and excellence in the field of state and local taxation
  • The Legal 500

Community


  • American Bar Association, Tax Section, former chair of the State and Local Tax Committee
  • Member, Board of Advisors, Journal of Taxation and Regulation of Financial Institutions
  • Member, Multistate State Tax Advisory Board, Tax Management Multistate Tax Report

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Credentials


Education
Stanford Law School – Stanford University
University of Pennsylvania

Admissions
California

Courts / Agencies
Supreme Court of the United States
US Tax Court

Roy E. Crawford

Insights & Events / Media

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