Mario J. Verdolini
  1. Partner

Mr. Verdolini is a partner in Davis Polk’s Tax Department and heads the firm’s tax litigation practice. He regularly represents clients in litigation and other tax controversies, focusing on administrative proceedings and settlements, trials, appeals and risk management, as well as grand jury, governmental and internal investigations. Mr. Verdolini has represented a wide range of domestic and foreign clients, including financial institutions and manufacturing, media and pharmaceutical companies.

Mr. Verdolini also plays a lead role in Davis Polk’s pro bono tax practice and has advised numerous exempt organizations.

Work Highlights

Tax Litigation
  • Obtained complete victory in U.S. Tax Court in debt/equity case for a consumer products company, after government won a string of other debt/equity cases
  • Obtained complete victory in Court of Federal Claims and Court of Appeals for the Federal Circuit in tax treaty case for a U.K. bank
  • Settled U.S. Tax Court case involving tax treatment of financial derivatives for media company
  • Representing consumer products companies in U.S. Tax Court cases involving domestic manufacturing deductions
  • Representing diversified multinational company in tax refund case in U.S. District Court involving tax treatment of corporate reorganization
Other Notable Representations
  • A telecommunications company in tax sharing arbitrations
  • An industrial company in connection with an SEC investigation into its accounting for taxes
  • An accounting firm and its partners in providing testimony in U.S. Tax Court, U.S. District Court and Court of Federal Claims in tax credit cases
  • A financial institution in connection with a grand jury investigation into tax shelters
  • A national law firm in connection with a grand jury investigation relating to tax opinions

Many of Mr. Verdolini’s most successful matters have resulted in favorable settlements or complete concessions by the government and remain confidential.


Mr. Verdolini is recognized as a leading tax lawyer in:

  • Chambers USA – Tax: Controversy: Nationwide | 2020
  • International Tax Review – Tax Controversy Leader | 20142017
  • Who's Who Legal: Corporate Tax (Controversy)

Of Note

  • Author, “The Objectivity of the Reasonable Basis Defense to Tax Penalties,” Tax Notes, January 2020
  • Elder, The Brick Presbyterian Church in the City of New York


Professional History

  • Partner, 1997-present
  • Associate, 1990-1997

Practice Focus

Bar Admissions

  • State of New York
  • U.S. Court of Appeals, Federal Circuit
  • U.S. District Court, Connecticut
  • U.S. District Court, S.D. New York
  • U.S. Court of Federal Claims
  • U.S. Tax Court


  • B.A., Yale University, 1985
    • cum laude
  • J.D., New York University School of Law, 1990
    • Order of the Coif