Peter M. Price is a partner in the Tax Controversy practice of the Chicago office. Peter represents and advises clients in all phases of tax controversy, including IRS audits, administrative appeals before the IRS Appeals Division, and litigation before federal courts. Peter’s experience includes complex corporate and partnership tax disputes including leasing transactions, purchase price allocations, economic substance issues, substance-over-form disputes, and intercompany transactions, including transfer pricing disputes.
His litigation experience includes matters in the United States Tax Court, the Northern District of Illinois, United States Court of Federal Claims, and United States Courts of Appeals. He joined Mayer Brown in 2009.
Mayer Brown was recently named Tax Controversy Team of the Year for the second consecutive year in the Legal 500 United States Awards. “Mayer Brown is ‘among the best’ and fields a large team…dedicated exclusively to tax controversy and transfer pricing,” said Legal 500 and its sources in the US edition.
The firm is “regularly seen in the most high-profile controversy cases before the US Tax Court” and produced “yet another impressive run of work” in 2014.
Education :
- Northwestern University School of Law, JD, cum laude
- University of Saint Thomas, BA, cum laude
Admissions : Illinois
Experience :
- Tribune Media Company F.K.A. Tribune Company & Affiliates v. Commissioner of Internal Revenue, T.C. Docket No. 20940-16 (tax treatment of leveraged partnership transaction).
- Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5501-12 (IRC § 482 reallocations).
- Boston Scientific Corporation v. Commissioner of Internal Revenue, T.C. Docket No. 26876-11 (IRC § 482 reallocations).
- Coffman v. United Sates, Docket No. 1:14-cv-06749 in the Northern District of Illinois (trust fund recovery penalty, settled before decision April 8, 2015)
- Potomac Electric Power co. & Subsidiaries v. United States, Docket No. 12-19 and PCI Holdings, Inc. & Subsidiaries v. United States, Docket No. 12-23 in the United States Court of Federal Claims (tax claim regarding PEPCO’s SILO Transactions, settled before decision May 11, 2015).
Cost
Rate : $$$
