Kacie Dillon
Attorney
Location: Las Vegas, Nevada, Salt Lake City, Utah, San Diego, California and Scottsdale, Arizona
Kacie Dillon represents clients in all aspects of federal and state tax controversy matters, including business, individual, employment and gift/estate tax audit defense, captive insurance, conservation easements, and significant collection matters. Ms. Dillon has significant tax litigation experience on complex tax matters. Ms. Dillon was lead counsel in the first litigated 831(b) captive insurance case tried in the United States Tax Court and has tried four additional 831(b) captive cases since.
Bar Admissions
- Arizona, 2007
- District Court of Arizona, 2007
- Unites States Tax Court, 2008
- United States Court of Appeals for the Federal Circuit, 2014
- Unites States Court of Federal Claims, 2019
Education
- University of Nebraska, College of Law, Lincoln, NE, graduated with Distinction, May, 2007
- Nebraska Wesleyan University, Lincoln, NE, May, 2004
- Major: Accounting
Representative Cases
- CD Listening Bar, Inc., et al., v. Commissioner, Dkt. 11369-16, et al., opinion pending. (831(b) captive insurance case involving a pool.)
- CFM Insurance, Inc. et al., v. Commissioner, T.C. Memo. 2025-83 (Aug. 5, 2025). (831(b) captive insurance case not involving a pool.)
- Schwarz v. Commissioner, T.C. Memo. 2024-55 (May 13, 2024), Supplemental Opinion T.C. 2025-122 (Nov. 24, 2025). (Hunting and fishing business vs. hobby.)
- Keating, et al., v. Commissioner, T.C. Memo. 2024-2 (Jan. 4, 2024). (831(b) captive insurance case involving a pool.)
- Oropeza v. Commissioner, 155 T.C. 132 (Oct. 13, 2020). (IRS failed to comply with section 6751(b) for penalty asserted regarding captive insurance transaction lacking economic substance and 20% penalties.)
- Oropeza v. Commissioner, T.C. Memo. 2020-111(July 21, 2020). (IRS failed to comply with section 6751(b) for penalty asserted regarding captive insurance transaction lacking economic substance.)
- Wilson et al. v. Commissioner, Dkt. 26547-13, 26548-13, 15011-14, 16759-14, case settled (Third litigated 831(b) captive insurance case).
- Avrahami v. Commissioner, 147 T.C. 144 (Aug. 21, 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).
- Householder v. Commissioner, T.C. Memo. 2018-136 (Aug. 23, 2018). (Horse business vs. hobby).
- Cave Buttes, LLC v. Commissioner, 147 T.C. 338 (Sept. 20, 2016), decision for the taxpayer. (Charitable contribution valuation and substantial compliance with Income Tax Regulations).
Classes/Seminars
- Presenter: IRS and Captives – Today and Tomorrow, March 2026
- Presenter: IRS Audits – Now and the Future, CICA, March, 2025
- Presenter: Combatting IRS Captive Challenges, CICA, March, 2024
- Presenter: Small Captive Tax Audits and Litigation Today’s Status, Tomorrow’s Changes, CICA, March 2023
- Presenter: Maximizing Results in Small Captive Tax Audits and Litigation, CICA, March 2022
- Presenter: Small Captive Tax Audits and Litigation – The Rest of the Story, CICA, March 2021
- Presenter: How to Navigate a Small Captive Tax Case, CICA, March 2020
- Presenter: The IRS is Concerned About Abuse and Small Captives, American Bar Association, Tax Section, May, 2019
- Presenter: Big Tax Insights on Small Captives, CICA March, 2019
- Presenter: Captive Insurance Companies after Avrahami: What Happens Next?, American Bar Association, Tax Section, February, 2018
- Presenter: Effectively Representing Your Clients Before the IRS During an Audit, 2018
- Presenter: Tax Topics for Individuals, APA Seminar, 2017
- Presenter: Developing Audit Cases – The Status and Activities of Captive Owners Going to Court Against the IRS, Delaware Captive Insurance Association, May, 2017
- Presenter: Small Captives, Big Issues: A Discussion of 831(b) from Audit to Appeals to the Courtroom, State Bar of Arizona, May, 2017
- Presenter: A Town Hall Meeting with the IRS, Western Regional Captive Insurance Conference, May 2016
- Presenter: Insurance Risk v. Non-Insurance Risk, Western Regional Captive Insurance Conference, May 2016
- Presenter: Successfully Dealing with IRS Collection Division, 2014
Honors and Awards
- Super Lawyers Rising Star
- Southwest Super Lawyers
Professional Associations and Memberships
- Arizona State Bar, Tax Section, Chairman
- Arizona State Bar, Tax Section, Vice Chair
- Arizona State Bar, Tax Section, Treasurer
- Arizona State Bar, Tax Section, Secretary
- Arizona State Bar, Tax Section, Program Coordinator
- American Bar Association, Tax Section
Past Employment Positions
- Woolston & Tarter, P.C.
- Farhang and Medcoff
- Frazer, Ryan, Goldberg and Arnold