Doug Sigel has 29 years of experience litigating and settling disputes in hearings and courts across the country. His practice focuses on state and local taxation, with an emphasis on litigation at the administrative, trial, and appellate levels. Examples of the types of matters Doug handles include sales and use tax, state corporate income tax (including the Texas margin tax), Texas property tax, motor vehicle sales tax, oil and gas severance tax, insurance tax, motor fuels tax, mixed beverage tax, unclaimed property, tax credits/incentives, nexus disputes, audits, hearings, trials and appeals, tax collection cases, voluntary disclosure agreements, letter rulings, and open records requests.

Practice Group Leader: Sales & use and Income Tax
Doug handles his docket of administrative, district court, and appellate cases in an aggressive yet efficient manner and always seeks the best outcome possible for his clients. Doug strives to streamline the resolution of his cases through innovative approaches tailored for each individual case. Doug creates innovative and unique strategies for each of his cases by first gaining a thorough understanding of the issues, personalities, and facts early in a dispute. With this foundation, Doug crafts a strategy to achieve an expedited settlement of the dispute through a collaborative interaction with counsel for the taxing authority. If necessary, Doug will take the case to trial as quickly as possible and leverage the strengths of the taxpayer’s position and evidence to present the taxpayer’s argument in a focused and creative manner.

Doug has spoken on a variety of sales and use and income tax topics at seminars sponsored by IPT, COST, TEI, The Hartman Forum, the Texas Society of CPAs, the Tulane Tax Institute, the State Bar of Texas, the National Association of State Bar Tax Sections, and the ABA Tax Section. He is also a frequent author on state and local tax topics. For example, Doug has authored a chapter for the IPT Income Tax Deskbook published in 2012.

Doug is on the executive board of the state and local tax committee of the ABA tax section. He is IPT’s overall chair for sales tax. He was the chair of the 2014 IPT Sales and Use Tax Symposium and is on the planning committee for the 2015 ABA/IPT Sales Tax Seminar. He is also the chair of the National Association of State Bar Tax Sections.

Areas of Expertise

Corporate Franchise & Income Tax
Sales & Use Tax
Education
  • J.D., University of Texas School of Law
  • B.S., Northwestern University
Professional Experience
Current
  • Practice Group Leader, Ryan Law Firm, LLP
Previous
  • Partner, Scott Douglas & McConnico, LLP, Austin
  • Debate Coach, Dartmouth College, Hanover, New Hampshire

Representative Matters
  • Successfully represented several hundred taxpayers over a span of two decades in sales and use, income/franchise, insurance, oil and gas severance, mixed beverage, and motor fuels tax cases at the administrative, trial, and appellate levels.
  • Successfully litigated numerous cases involving the Texas sale-for-resale exemption or the manufacturing exemption and obtained hundreds of millions of dollars of refunds in those cases. For example, Doug (1) obtained dozens of large sales tax refunds for defense contractors of tax paid on items charged to federal contracts after successfully litigating those issues in the Raytheon and Health Care Services Corporation cases listed below, (2) obtained a refund of tax paid on purchase of electrical transportation and distribution equipment after successfully litigating the issue in the El Paso Electric case listed below, and (3) obtained refunds of tax paid for a hotel’s purchases of consumables used by guests after successfully litigating the issue in the DTWC case listed below.
  • Currently litigating two manufacturing exemption cases in Texas courts.
  • Handled dozens of audits and administrative hearing. For example, Doug eliminated through settlement a $5 million tax collected but not remitted assessment by the Texas Comptroller against a large construction contractor.
  • Successfully defended taxpayers in numerous nexus cases involving sales tax or franchise tax.
  • Successfully defended tax collection cases at the administrative and trial court levels.
  • Handled several cases involving complex procedural issues such as statute of limitations defenses, second refund claim issues, pleas to the jurisdictions regarding exhaustion of administrative remedies, challenges to the Texas Comptroller’s refund claim rules, and interpretation and enforcement of managed audit and settlement agreements.
  • Handled cases in states of Texas, New York, California, Illinois, Florida, Georgia, Maryland, Ohio, Pennsylvania, New Jersey, Missouri, New Mexico, Minnesota, Arkansas, Tennessee, Louisiana, Washington, Nevada, and Nebraska.
  • Handled many appeals at both the Court of Appeals and Supreme Court levels in numerous states.
Professional / Civic Affiliations
Current
  • Institute for Professionals in Taxation (IPT)
  • American Bar Association Tax Section, Executive Board of the State and Local Tax Committee
  • Austin Bar Association
  • Public Service
  • Counsel to Texas Ambulance Association for over 15 years
Recent Articles And Upcoming Presentations
  • “How Will Wayfair Affect You?,” IPT Wayfair Webinar, October 2018
  • “SUT Controversy Part II: Litigating a Sales and Use Tax Case,” 2018 IPT Sales Tax Symposium, September 2018
  • “Advocacy Update – Recent and Pending Comptroller Litigation, Administrative Hearings, and Procedural Rule Changes,” 2018 TSCPA Texas State Taxation Conference, August 2018
  • “Significant Developments and Decisions in Sales Taxation,” IPT 42nd Annual Conference, June 2018
  • “Preparing for Audit Challenge and Controversy,” COST 2018 Intermediate/Advanced State Income Tax School Session, May 2018
  • “Understanding and Challenging Tax Regulations and Other Administrative Guidance,” 2018 ABA/IPT Sales/Use Tax Seminar, March 2018
  • “Planning For and Defending Against Transfer Pricing Adjustments,” 2018 ABA/IPT Advanced State Income Tax Seminar, March 2018
  • “Cloud Computing – Current Sales and Tax Issues,” 2017 Joint Fall CLE Meeting, September 2017
  • “Litigating a Sales and Use Tax Case,” 2017 IPT Sales Tax Symposium, September 2017
  • “The Current State of the Texas Franchise Tax,” IPT Insider, August 2017
  • “Panel: Hot Topics and Current Developments in Sales and Use Tax,” Georgetown SALT Institute, July 2017
  • “Year in Review – Top 10 Sales and Use Tax Cases,” IPT 41st Annual Conference, July 2017
  • “Ultimate Remedies: Litigation Techniques,” IPT Midwest Manufacturing Tax Workshop, June 2017
  • “Preparing for Audit Challenge and Controversy,” COST 2017 Intermediate/Advanced State Income Tax School Session, May 2017
  • “Top 10 Income Tax Cases” and “Dealing with the Difficult Audit and Preparing for Appeal/Litigation in Court and in Appeals Court,” 2017 AB A/IBT Advanced Tax Seminar, March 2017
  • “The Texas Cost of Goods Sold Deduction – A Movie Theatre May Deduct Film Exhibition Costs Because Film Exhibition is ‘Tangible Personal Property’,” IPT Insider, February 2017
  • “Industry Issues: Oil & Gas,” 2016 IPT Sales Tax Symposium, September 2016
  • “Update on Texas Margin Tax: Plain Meaning Wins,” IPT Insider, June 2016
  • “Ask the Experts – TX, LA,” IPT 40th Annual Conference, June 2016
  • “The Year In Review – Top Cases,” IPT 40th Annual Conference, June 2016
  • “Broadening Horizons: Exemptions for Non-Traditional Manufacturers,” 2016 ABA/IPT Advanced Tax Seminars, March, 2016
  • “Top Ten Recent Legislative Enactments and Judicial Decisions Affecting Income Taxation,” 2016 ABA/IPT Advanced Tax Seminars, March 2016
  • “What Can Ohio Learn from the Texas Franchise Tax and the Washington Business and Occupations Tax?,” Manufacturers’ Education Council 25th Annual Ohio Tax Conference, January 2016
  • “Significant Texas State and Local Taxation Cases,” NYU 34th Institute on State and Local Taxation, December 2015
  • “Prominent Court Cases that will Affect Taxes and How They Are Paid: American Multi-Cinema, Inc. v. Combs, et al.,” Texas Taxpayers and Research Association Annual Meeting, October 2015
  • “Industry Issues – Oil & Gas,” IPT Sales Tax Symposium, September 2015
  • “Ask the Experts – South Central,” IPT Sales Tax Symposium, September 2015
  • “Broadening Horizons: Exemptions for Non-Traditional Manufacturers,” IPT Manufacturing & Related Industries: SALT Workshop, July 2015
  • “Top 10 Tax Issues,” 2015 IPT Annual Conference, June 2015
  • “Mock Congressional Hearing – Taxation of Remote Sellers,” 2015 IPT Annual Conference, June 2015.
  • “Preparing for Audit Challenges and Controversy,” COST 2015 Intermediate/Advanced State Income Tax School, May 2015.
  • “Traps for the Unwary in Dealing with the Major Business Taxes – Income, Gross Receipts and Margin Taxes,” ABA/IPT Advanced Income Tax Seminar, March 2015
  • “Economic Substance, Sham Transactions,” ABA/IPT Advanced Sales/Use Tax Seminar, March 2015
  • “How Are the Economic Substance Doctrine and Related Principles Being Applied in State Tax Cases?,” ABA Section of Taxation State Tax Committee, January 2015
  • “Current Developments for May 2014 through August 2014,” ABA Tax Section State & Local Tax Committee, September 2014
  • “Update on Texas Margin Tax: Decisions Affecting the Cost of Goods Sold Deduction,” IPT Tax Report, September 2014
  • “Defining Value: How Far Can the Texas Legislature Constitutionally Go?,” 28th Annual Legal Seminar on Ad Valorem Taxation, August 2014
  • “Manufacturing Exemptions and Incentives across Tax Types SUT, FT (COGS and Tax Rate), Property Tax, and More,” TSCPA 2014 State Taxation Conference, August 2014
  • “Oil and Gas Update: New Developments and Issues,” TEI State and Local Roundtable, June 2014
  • “Current Developments in Sales and Use Taxation,” 2014 IPT 38th Annual Conference, June 2014
  • “District court Rules Texas Taxpayers Cannot Elect to Use Three-Factor MTC Apportionment in Lieu of Texas’ Single-Factor Apportionment,” IPT Tax Report, March 2014
  • “Successful Litigation Strategies,” ABA/IPT Advanced Income Tax Seminar, March 2014
  • “Update on Other Business Taxes (Ohio, Washington, and Texas),” ABA/IPT Advanced Income Tax Seminar, March 2014
  • “Property Tax Issues West of the Mississippi,” 2014 COST Property Tax Workshop, January 2014
  • “Current Developments/Hot Topic in Exemptions from Sales/Use Taxes,” 20th Annual Paul J. Hartman State and Local Tax Forum, October 2013
  • “Sourcing for State Sales Tax and Income Apportionment,” National Association of State Bar Tax Sections 34th Annual Meeting, October 2013
  • “Plain Meaning or Ambiguity: What Did the Judges Say – and What Does it Mean for Texas Taxpayers?,” TSCPA 2013 Texas State Taxation Conference, August 2013
  • “Update on Texas Court Cases Involving the Sale-for-Resale Exemption,” IPT Tax Report, July 2013
  • “Sales Tax Implications of the Integrated Plant Theory,” 2013 IPT 37th Annual Conference, June 2013
  • “Is it Possible to Get Uniformity in Property Taxation?,” 2013 COST Property Tax Workshop, January 2013
  • “Top 10 Sales Tax Cases of 2012,” 2012 Paul J. Hartman State and Local Tax Forum, November 2012
  • “Nexus Update on the 20th Anniversary of the Quill Decision,” 2012 Advanced Sales and Use Tax Academy, November 2012
  • “National Trends/Updates in State and Local Taxation,” 61st Tulane Tax Institute Program Schedule, October 2012
  • “Oh No, They Didn’t: Procedural Roadblocks in Obtaining Refunds,” National Association of State Bar Tax Sections 33rd Annual Meeting, October 2012
  • “Pitfalls and Planning Opportunities,” TSCPA 2013 State Taxation Conference, August 2012
  • “Cutting Edge Issues Regarding Manufacturing Exemptions from Sales and Use Taxes,” ABA Tax Section State & Local Tax Committee, September 2012
  • “Economic Substance and Business Purpose in State Taxation: Current Judicial and Statutory Trends,” IPT Annual Conference, June 2012
  • “Recent Texas Sales and Use Tax Cases,” IPT Tax Report, May 2012
  • “Emerging Issues – Cases in the Pipeline,” ABA/IPT Advanced Income Tax Seminar, March 2012
  • “Update on Constitutional Litigation Regarding the Texas Margin Tax,” IPT Tax Report, December 2011
  • “The ‘Other’ Business Taxes – Michigan, Ohio, and Texas,” IPT Income Tax Symposium, November 2011
  • “Texas Supreme Court Case Involving Apportionment of Geophysical and Seismic Data,” IPT Tax Report, July 2011
  • “Sales and Use Tax Aspects of Government Contracting,” ABA Tax Section May Meeting, May 2011
  • “Recent Court Case Involving the Texas Sale-For Resale Exemption,” IPT Tax Report, April 2011
  • “Using TPP to Provide Services – What is Taxable and What is Not?; Bundled vs. Mixed Transactions,” ABA/IPT Advanced Income Tax Seminar, March 2011
  • “Update on Court Cases Involving the Texas Manufacturing Exemption,” IPT Tax Report, January 2011
  • “Voluntary Disclosure – Don’t Get Hit By a Big Stick When You Go After the Carrot,” Advanced Sales and Use Tax Academy, November 2010
Selected Pending Texas Appellate Cases
  • Petroquest Energy, LLC v. State of Oklahoma, Cause No. TC-115969, In the Supreme Court of Oklahoma
  • Alamo Natl. Building Management, LP v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, Cause No. 13-17-00040-CV (Tex. App. – Corpus Christi [13th Dist.] 2017)
  • Dallas World Aquarium Corp. v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas, Cause No. 03-18-00209-CV (3rd Cir. 2018 – Austin, TX)
  • CEC Entertainment, Inc. v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, Cause No. 03-18-00375-CV (3rd Cir. 2018 – Austin, TX)
  • Instill Corporation v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, Cause No. 03-18-00374-CV (3rd Cir. 2018 – Austin, TX)
  • Glenn Hegar, Comptroller of Public Accounts of the State of Texas v. Duncan Burch, Inc., Cause No. 03-18-00277-CV (3rd Cir. 2018 – Austin, TX)
  • Badger Tavern, L.P. v. Glenn Hegar, Comptroller of Public Accounts, et al., Cause No. 03-18-00291-CV (3rd Cir. 2018 – Austin, TX)
  • Glenn Hegar, Comptroller of Public Accounts of the State of Texas, et al., v. El Paso Electric Co., Cause No. 03-18-00790-CV (3rd Cir. 2018 – Austin, TX)
Selected Pending Texas Supreme Court Cases
  • Glenn Hegar, Comptroller of Public Accounts of the State of Texas v. Badger Tavern, L.P., Cause No. 18-1149 (On Petition for Review)
  • Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas v. American Multi-Cinema, Inc., Cause No. 17-0464 (On Petition for Review)
  • Lockheed Martin Corporation v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, Cause No. 18-0566 (On Petition for Review)
  • Nabors Drilling Technologies USA, Inc., Successor by Merger to Ryan Directional Services, Inc. v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, Cause No. 18-0565 (On Petition for Review)
Selected Reported Cases
  • Reeves County Appraisal District, et al., v. Midcon Compression, L.L.C., Case No. 15-0969, 2018 WL 6004942 (Tex. Sup. Ct. – November 16, 2018)
  • Badger Tavern, L.P. v. Hegar, et al., Cause No. 03-18-00291-CV, 2018 WL 4322383 (Tex. App. – Austin, September 11, 2018)
  • Lockheed Martin Corp. v. Hegar, et al., Cause No. 03-16-00303-CV, 2018 WL 2750061 (Tex. App. – Austin, June 8, 2018)
  • Nabors Drilling Technologies USA, Inc. v. Hegar, et al., Cause No. 03-17-00284-CV, 2018 WL 2709201 (Tex. App. – June 6, 2018)
  • EMC Corp. v. Hegar, et al., Cause No. 03-15-00113-CV, 2018 WL 1770997 (Tex. App. – Austin, April 13, 2018)
  • Graphic Packaging Corp. v. Hegar, et al., Case No. 15-0669, 2017 WL 6544951 (Tex. Sup. Ct. – December 22, 2017)
  • Cantu Enterprises, LLC v. Hegar, et al., Cause No. 03–15–00516–CV, 2017 WL 2927567 (Tex. App. – Austin, July 7, 2017)
  • Allstate Insurance Company v. Combs, et al., Cause No. 03–13–00341–CV, 2016 WL 690822 (Tex. App. – Austin, May 17, 2017)
  • Owens Corning v. Hegar, et al., Cause No. 04-16-00211-CV, 2017 WL 1244444 (Tex. App. – San Antonio, April 5, 2017)
  • Fitness International, LLC v. Hegar, et al., Cause No. 03–15–00534–CV, 2016 WL 3391606 (Tex. App – Austin, June 16, 2016)
  • Skyline EMS, Inc., et al. v. AR Concepts Inc., Cause No. 04-15-00070-CV, 2015 WL 7566247 (Tex. App. – San Antonio, November 25, 2015)
  • Combs, et al. v. Checkfree Services Corp., Cause No. 14–15–00027–CV, 2016 WL 1576414 (Tex. App. – Houston, April 19, 2016)
  • Hallmark Marketing Company, LLC v. Combs, et al., Case No. 14-1075, 2016 WL 1516774 (Tex. Sup. Ct. – April 15, 2016)
  • Hegar v. Ryan, LLC, Cause No. 03–13–00400–CV, 2015 WL 3393917 (Tex. App. – Austin, May 20, 2015)
  • American Multi-Cinema, Inc. v. Combs, et al., Cause No. 03–14–00397–CV, 2015 WL 1967877 (Tex. App. – Austin, April 30, 2015)
  • Gulf Chem. & Metallurgical Corp. v. Hegar, Cause No. 03–12–00772–CV, 2015 WL 1478195 (Tex. App. – Austin, March 26, 2015)
  • Combs v. Ryan, L.L.C., Cause No. 03–13–00400–CV, 2015 WL 3393917 (Tex. App. – May 20, 2015)
  • Combs, et al. v. Imperial Fire and Casualty Insurance Company, Cause No. 03–13–00576–CV, 2015 WL 1026056 (Tex. App. – Austin, March 4, 2015)
  • Hallmark Marketing Company, LLC v. Combs, et al., Cause No. 13–14–00093–CV, 2014 WL 6090574, (Tex. App. – Corpus Christi-Edinburg, Nov. 13, 2014)
  • Southwest Royalties, Inc. v. Combs et al., Cause No. 03–12–00511–CV, 2014 WL 4058950 (Tex. App. – Austin, August 13, 2014)
  • Combs, et al. v. Fair Isaac Corp., Cause No. 03-14-00124-CV, 2014 WL 3893075 (Tex. App. – Austin, August 8, 2014)
  • AETC II Privatized Housing, L.L.C., v. Tom Green County Appraisal District, Cause No. 03–13–00463–CV, 2015 WL 3918619 (Tex. App.— Austin, July 10, 2013)
  • Combs, et al. v. Health Care Services Corp., Case Nos. 11-0283, 11-0652, 2013 WL 2663985 (Tex. Sup. Ct. – June 7, 2013)
  • DTWC Corp. v. Combs, et al., Cause No. 03–10–00801–CV, 2013 WL 1568513 (Tex. App. – Austin, April 11, 2013)
  • Leoncito Plant, L.L.C., v. Combs, Cause No. 07–12–0295–CV, 2013 WL 1460195 (Tex. App. – Amarillo, April 10, 2013)
  • Verizon Business Network Services, Inc. v. Combs, et al., Cause No. 07–11–0025–CV, 2013 WL 1343530 (Tex. App. – Amarillo, April 3, 2013)
  • In re the State of Texas, Cause No. 03–12–00370–CV, 2012 WL 3793142 (Tex. App. – Austin, Aug. 30, 2012)
  • Bell Helicopter Textron, Inc. v. Combs, et al., Cause No. 03–10–00764–CV, 2011 WL 6938491 (Tex. App. – Austin, December 29, 2011)
  • Combs, et al. v. Health Care Service Corp., Cause No. 03–10–00675–CV, 2011 WL 2652141 (Tex. App. – Austin, July 7, 2011)
  • State v. BFI Waste Services of Texas, LP, Cause No. 03–10–00504–CV, 2011 WL 1086585 (Tex. App. –Austin, March 23, 2011)
  • Combs, et al. v. Health Care Service Corp., Cause No. 03–09–00617–CV, 2011 WL 1005419 (Tex. App. –Austin, March 16, 2011)
  • Combs, et al. v. Frito Lay, Inc., Cause No. 03-11-00157-CV (Tex. App. – Austin, March 14, 2011)
  • Alcoa World Alumina, L.L.C. v. Weiss, Case No. 09-688 (Ala. Sup. Ct. – February 25, 2010)
  • Combs, et al. v. El Paso Elec. Co., Cause No. 03-10-00443-CV, 2010 WL 4910052 (Tex. App. – Austin, December 1, 2010)
  • GTE Southwest Inc. v. Combs, et al., Cause No. 03-08-00561-CV, 2010 WL 2218662 (Tex. App. – Austin, June 3, 2010)
  • Combs, et al. v. Chevron, Inc., Cause No. 03–07–00127–CV, 2010 WL 1404670 (Tex. App. – Austin, April 9, 2010)
  • Reynolds Metals Co. v. Combs, et al., Cause No. 03-07-00709-CV, 2009 WL 961615 (Tex. App. – Austin, April 8, 2009)
  • Southwestern Bell Yellow Pages v. Combs, et al., Cause No. 03–07–00638–CV, 2009 WL 211633 (Tex. App. – Austin, January 30, 2009)
  • Goodyear Tire & Rubber Co. v. State, Case No. S–06–1103, 2008 WL 1947576 (Neb. Sup. Ct. – May 2, 2008)
  • Af-Cap, Inc. v. Republic of Congo, Case Nos. 05–50290, 05–50782 and 05–51168, 2006 WL 2424778 (5th Cir. 2007).
  • In the Matters of the Protest of Support Terminals Operating Partnership, Case No. 2003-14, 2006 WL 1806400 (N.M. TaxRw. Dept., 2006)
  • El Paso Natural Gas Co. v. Strayhorn, Cause No. 06–05–00059–CV, 2006 WL 2975309 (Tex. App. – Texarkana, October 18, 2006)
  • Tyson Fresh Meats, Inc. v. State, Case No. S-04-1294, 2005 WL 2675662 (Neb. Sup. Ct. – October 21, 2005)
  • Local Neon Co., Inc. v. Strayhorn, Cause No. 03-04-00261-CV, 2005 WL 1412171 (Tex. App. – Austin, June 16, 2005)
  • Walker Int’l Holdings, Ltd. v. Republic of Congo, Case No. 04-20301, 2004 WL 2958313 (5th Cir. 2005)
  • Strayhorn v. Willow Creek Resources, Inc., Cause No. 03–04–00629–CV, 2005 WL 670537 (Tex. App. –Austin, March 24, 2005)
  • May Dept. Stores Co. v. Strayhorn, Cause No. 03-03-00729-CV, 2004 WL 1898244 (Tex. App. – Austin, August 26, 2004)
  • Strayhorn v. Raytheon E-Systems, Inc., Cause No. 03–02–00346–CV, 2003 WL 192105 (Tex. App. – Austin, January 30, 2003)
  • Sergeant Enterprises, Inc., v. Strayhorn, Cause No. 03–03–00047–CV, 2003 WL 21554352 (Tex. App. – January 17, 2003)
  • B.F. Goodrich W. v. McCorkle, Cause No. A14–93–00772–CV, 1993 WL 471498 (Tex. App. – Houston, November 18, 1993)
Admitted to Practice
  • State Bar of Texas
  • United States Tax Court
  • United States Court of Appeals for the Fifth Circuit
  • United States District Court – Eastern District of Texas
  • United States District Court – Southern District of Texas
  • United States District Court – Western District of Texas