FacultyFaculty/Author Profile
Jean A. Pawlow

Jean A. Pawlow

McDermott Will & Emery LLP

Washington, DC, USA


Jean A. Pawlow is a partner in the law firm of McDermott Will & Emery LLP based in the Washington, D.C. office.  She is a member of the U.S. & International Tax Practice Group and the chair of the Tax Controversy Practice.

Jean has been involved in representing businesses and individuals on significant tax controversy matters for twenty five years.  Substantive issues in dispute have included transfer pricing issues under Code section 482, tax advantaged transactions, tax accounting issues, insurance tax matters, the tax treatment of financial instruments, foreign tax credit and research credit issues, leveraged leases, credit card interchange and original issue discount (OID), excise taxes, reasonable compensation, estate and gift tax issues, and charitable contribution deductions.

Jean has litigated cases before the U.S. Tax Court, the Court of Federal Claims, U.S. District Courts, U.S. Courts of Appeal, and the Supreme Court. She also has extensive experience with IRS alternative dispute resolution (ADR) procedures, including Fast Track Settlement, Rapid Appeals, Post-Appeals Mediation, Pre-Filing Agreements, and CAP audits.  She also represents clients who are being audited by the Service’s Global High Wealth Industry Group.

Jean is a frequent writer and speaker on tax controversy matters and has appeared on CBS and CNBC.  The Legal 500 has named Jean a “leading lawyer” every year since 2009, and quoted a client who described her as “A pleasure to work with, clever, an excellent advocate, personable and possessed of an instinctive business understanding.” She was nationally ranked as a leading tax litigation lawyer in the 2010, 2011, 2012, and 2013 editions of Chambers USA as “one of the preeminent tax lawyers in the U.S.” and noted for her “dedication to client service.”  Jean was also listed in Best Lawyers in America 2012, 2013, and 2014.

Representative Docketed Cases:

  • Estate of Stanton v. Commissioner (Tax Ct. filed Aug. 15, 2013).
  • John Hancock Life Ins. Co. v. Commissioner, 141 T.C. No. 1 (2013).
  • Siemens Corp. v. Office of Tax and Revenue, No. 2013-OTR-00010 (Dist. of Columbia filed Apr. 11, 2013).
  • Novitsky v. Siemens Corp., No. MIDL-2614-13 (D.N.J. filed Apr. 22, 2013).
  • United Services Automobile Association (“USAA”) v. United States, No. 10-cv-00185 (W.D. Tex. filed Mar. 5, 2010) and USAA v. Commissioner, No. 021037-10 (Tax Ct. filed Sept. 21, 2010).
  • Capital One Fin. Corp. v. Commissioner, 659 F.3d 316 (4th Cir. 2011), aff’g, 133 T.C. 136 (2009) and 130 T.C. 147 (2008).
  • John Hancock Life Ins. Co. v. United States, No. 09-31169 (5th Cir. filed Mar. 3, 2010)
  • Goodrich Corp. v. United States, 2012 U.S. Dist. LEXIS 5301 (W.D. N.C. Jan. 18, 2012) and Goodrich Corp. v. Commissioner, No. 29180-09 (Tax Ct. filed Dec. 8, 2009).
  • Nat’l R.R. Passenger Corp. (“Amtrak”) v. United States, 338 F. Supp. 2d 22 (D.D.C. 2004), aff’d, 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) aff’g, 258 F.3d 958 (9th Cir. 2001), rev’g, 82 A.F.T.R.2d (RIA) 6246 (W.D. Wash. 1998).
  • Wal-Mart Stores, Inc. v. Commissioner, T.C. Memo 1997-1, aff’d, 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, 98 T.C. 628 (1992) and T. C. Memo. 1992-306 (1992)

Practice Area/Industries

  • Tax
  • Tax Controversy
  • Transfer Pricing
  • Trust & Estate Controversy

Education

  • Harvard Law School, J.D. cum laude, 1988
  • University of California at Berkeley, B.S. with high honors, 1985
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