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 U.S. & International Tax Practice Group and the chair of the Federal Tax Controversy Practice.
Jean has been involved in significant tax litigation matters for twenty five 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 transfer pricing issues under Code section 482, capitalization and change in method of accounting issues, foreign tax credit and research credit issues, and tax advantaged transactions including COLI, LILOs and SILOs, and distressed debt transactions.
Jean has extensive experience with the Internal Revenue Service's alternative dispute resolution (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.
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). — Interchange income earned by credit card issuer is OID
John Hancock Life Ins. Co. v. Commissioner, No. 7084-10 (Tax Ct. filed Mar. 23, 2010) and No. 6404-09 (Tax Ct. filed Mar. 17, 2009) — Whether taxpayer is entitled to rent or depreciation
and interest deductions on certain leveraged lease transactions.
Goodrich Corp. v. United States, No. 10-cv-0105 (W.D. N.C. filed Mar. 9, 2010) and Goodrich Corp. v. Commissioner, No. 29180-09 (Tax Ct. filed Dec. 8, 2009). — Whether taxpayer may deduct interst expense relating to
the transfer of propety to a trust for the benefit of the IRS
in satisfactio of a contested liability under code section 461(f)