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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 tax controversies, including tax litigation.
Prior to joining McDermott, Jean worked at a law firm based in Washington, D.C., where she was involved in some of the firm’s most significant tax litigation matters for nearly twenty years, including litigation concerning original issue discount (OID), the use of shrinkage estimates, DISC/FSC pricing, the communications excise tax, 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 included resolution of transfer pricing issues under Code section 482, including Advance Pricing Agreements and Competent Authority requests, the taxation of corporate owned life insurance (COLI), capitalization and change in method of accounting issues, and a variety of other taxation issues, including tax shelter transactions.
Jean has extensive experience with LMSB’s ADR procedures, including Fast Track Settlement, Post-Appeals Mediation, Pre-Filing Agreements, and LIFE audits.
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.
Representative Cases:
Nat’l R.R. Passenger Corp. (Amtrak) v. United States, 431 F.3d 374 (D.C. Cir. 2005)
Capital One. Fin. Corp. v. Commissioner, No. 195190-05 (Tax Ct. filed Oct. 18, 2005)
Barrick Res. (USA) Inc. v. United States, No. 2:03:CV01006 DB (D. Utah filed Nov. 17, 2003)
Boeing Co. v. United States, 537 U.S. 437 (2003)
Wal-Mart Stores, Inc. v. Commissioner, 153 F.3d 650 (8th Cir. 1998)
Metropolitan Life Ins. Co. v. United States, 30 Fed. Cl. 195 (1993)
Jean is admitted to practice in the District of Columbia and California.
Education
Harvard Law School, J.D. (cum laude), 1988
University of California-Berkeley, B.S. (with high honors), 1985 | 