Jean A. Pawlow is a partner in the law firm of McDermott Will & Emery LLP based in the Firm’s Washington, D.C. office. She is a member of the Tax Department, where she focuses on federal tax controversies. Jean has been involved in significant tax litigation matters for 20 years, including litigation concerning credit card interchange and original issue discount (OID), the use of shrinkage estimates, the telecommunications excise tax, DISC/FSC pricing, and the treatment of life insurance reserves. She has represented clients in disputes before the U.S. Tax Court, the Court of Federal Claims, U.S. District Courts, U.S. Courts of Appeal, the Internal Revenue Service Appeals Division, and the Internal Revenue Service National Office.
Substantive issues in dispute in these matters have also included resolution of transfer pricing issues under Code section 482, capitalization and change in method of accounting issues, foreign tax credit issues, and tax advantaged transactions including COLI, LILOs, and SILOs.
Jean has extensive experience with LMSB’s ADR procedures, including Fast Track Settlement, Post-Appeals Mediation, Pre-Filing Agreements, and LIFE and CAP audits, and she is a frequent speaker on tax controversy matters.
Jean was identified in an online survey completed by in-house tax professionals as “key to the tax services they receive” in the March 2007 edition of the International Tax Review. She was one of only eight lawyers recognized nationally in the U.S. for tax litigation in the 2008-2009 edition of Cross-Border Tax on Corporate Transactions Handbook. The Legal 500 recently commended Jean for her “instinctive business understanding” and “excellent service.”
Representative Cases:
- Capital One. Fin. Corp. v. Commissioner, No. 195190-05 (Tax Ct. filed Oct. 18, 2005)
- Nat’l R.R. Passenger Corp. (“Amtrak”) v. United States, 431 F.3d 374 (D.C. Cir. 2005)
- Barrick Res. (USA) Inc. v. United States, 464 F. Supp. 2d 1143 (D. Utah 2006)
- Boeing Co. v. United States, 537 U.S. 437 (2003)
- Wal-Mart Stores, Inc. v. Commissioner, 153 F.3d 650 (8th Cir. 1998)
- Cheng v. Commissioner and Pen v. Commissioner, Nos. 509-96 and 510-96 (Tax Ct. filed Jan. 11, 1996)
- Metropolitan Life Ins. Co. v. United States, 30 Fed. Cl. 195 (1993)
- Texas Instruments v. Commissioner, T. C. Memo 1992-306 (1992)
Education
- Harvard Law School, J.D. (cum laude), 1988
- University of California-Berkeley, B.S. (with high honors), 1985
