David Cowling has extensive transactional and tax controversy experience with taxing authorities throughout the United States and abroad. He chairs the Firm's State and Local Tax Practice and its e-Commerce Tax Practice.David has recently petitioned for certiorari at the United States Supreme Court both for a very complex Kansas property tax dispute involving natural gas in common carrier pipelines and an Alaska unitary income tax case. He is integrally involved in Delaware qui tam cases involving companies using gift cards and in several dozen pending audits and cases involving online travel companies. He is involved in appealing whether three factor apportionment is available in the Texas franchise tax. Recent tax controversy defense work includes the successful defense of an unusually large sales tax assessment of one of the largest e-commerce companies, defense of a substantial West Coast unitary assessment, and successful appeal of a very large municipal use tax assessment. David represents diverse e.commerce, financial services, energy, manufacturing, marketing, wholesaling, distribution, retailing, and services industry taxpayers.