Nathaniel S. Pollock Attorney

Nate focuses his practice on federal tax controversy, including tax litigation. Nate founded SouthBank Legal's tax controversy practice and represents companies and individuals at all stages of a tax dispute including IRS examinations, administrative appeals, post-appeals mediation, litigation either in the U.S. Tax Court, U.S. Court of Federal Claims, or U.S. district courts, and appellate litigation in the U.S. circuit courts of appeals. Nate also helps clients evaluate the litigation risk inherent in tax positions they are contemplating. Before joining SouthBank Legal, Nate was one of two senior level attorneys at the U.S. Department of Justice in the Tax Division's Appellate Section, where he was tasked with handling the government's most significant and challenging tax appeals. Nate won multiple awards from the Department of Justice for his outstanding work and exceptional results. Nate has litigated tax cases involving a range of issues, including: serious constitutional challenges to tax laws, Administrative Procedure Act challenges to Treasury Regulations, federal law treatment of the cannabis industry (Section 280E of the Code and cost of goods sold), international tax issues (interpretation of tax treaties, the mandatory repatriation act, transfer of intellectual property to a related foreign entity, etc.), challenges to denials of tax exempt status, the alternative fuel mixture credit, and much more. Nate has recently argued that medical cannabis businesses generally have a better Commerce Clause argument that section 280E should not apply than adult use cannabis businesses.