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Pete Lowy

Partner

Heritage Plaza
1111 Bagby Street
Suite 2100
Houston, TX 77002
peter.lowy@nelsonmullins.com

Peter is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers on tax compliance issues, tax planning, and risk management across industries. He regularly works with the U.S. Internal Revenue Service and the Texas Comptroller’s office.

During his career Peter has been responsible for...

Peter is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers on tax compliance issues, tax planning, and risk management across industries. He regularly works with the U.S. Internal Revenue Service and the Texas Comptroller’s office.

During his career Peter has been responsible for more than 200 tax cases that have cut across many types of taxes including U.S. federal income, excise, and employment taxes. Peter also has experience with state and local taxes, income, franchise, sales and use, severance, motor fuels, and property taxes. Peter has handled more than 10 cases with amounts in issue exceeding $100 million each, and two cases that exceeded $1 billion in issue. He also served as lead attorney in structuring several complex transactions including a multibillion-dollar, cross-border deal in the energy sector.

Dedicated throughout his career to pro bono work, Peter devotes substantial time each year to represent underprivileged taxpayers.

more than 200 tax cases that have cut across many types of taxes including U.S. federal income, excise, and employment taxes. Peter also has experience with state and local taxes, income, franchise, sales and use, severance, motor fuels, and property taxes. Peter has handled more than 10 cases with amounts in issue exceeding $100 million each, and two cases that exceeded $1 billion in issue. He also served as lead attorney in structuring several complex transactions including a multibillion-dollar, cross-border deal in the energy sector.

Dedicated throughout his career to pro bono work, Peter devotes substantial time each year to represent underprivileged taxpayers.

Peter is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers on tax compliance issues, tax planning, and risk management across industries. He regularly works with the U.S. Internal Revenue Service and the Texas Comptroller’s office.

During his career Peter has been responsible for... more than 200 tax cases that have cut across many types of taxes including U.S. federal income, excise, and employment taxes. Peter also has experience with state and local taxes, income, franchise, sales and use, severance, motor fuels, and property taxes. Peter has handled more than 10 cases with amounts in issue exceeding $100 million each, and two cases that exceeded $1 billion in issue. He also served as lead attorney in structuring several complex transactions including a multibillion-dollar, cross-border deal in the energy sector.

Dedicated throughout his career to pro bono work, Peter devotes substantial time each year to represent underprivileged taxpayers.

Experience

The following is a selected sampling of matters and is provided for informational purposes only. Past success does not indicate the likelihood of success in any future matter.

  • Co-author, Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, 4th Ed., Tax Management Portfolio Series (2017)
  • Speaker, Unveiling the Layers: Navigating Potential Tax Controversies Surrounding the Inflation Reduction Act, Texas State Bar Renewable Energy Tax Conference (2024)
  • Moderator, Energy Excise Taxes – We’re Back, Baby!, 16th Biennial Parker Fielder Oil & Gas Tax Conference (2023)
  • Panelist, Trying to Reach the Promised Land (Tips for Successful Refund Claims), LITC Grantee Conference Sponsored by Internal Revenue Service (2020)
  • Speaker, SALT & the New Property Tax Relief Act, Houston CPA Society Expo (2020)
  • Moderator, Changes & Developments in IRS Examination and Appeals, 15th Biennial Parker Fielder Oil & Gas Tax Conference (2019)
  • Panelist, Winning Valuation Cases, Tax Executive Institute, Houston Chapter (2019)
  • Speaker, Best Practices for Resolving Federal and State Tax Controversies, Houston Chapter, Monthly Luncheon (2018)
  • Speaker, Avoiding Ethical Pitfalls When Handling Tax Controversies, Houston Bar Association, Monthly Luncheon (2018)
  • Panelist, Witness Preparation, Tax Executive Institute, Houston Chapter, 2018 Tax School (2018)
  • Speaker, State and Local Tax Update, Houston CPA Society Expo (2018)
  • Speaker, Tax Controversy & Audit: The Impact of the New LB&I Campaign Strategy on the Oil & Gas Sector, 14th Biennial Parker Fielder Oil & Gas Tax Conference (2017)
  • Speaker, Tackling Texas Taxes, Tax Executive Institute, Houston Chapter, Monthly Luncheon (2017)

Education

  • New York University School of Law, LLM, Taxation (1997)
  • Tulane University Law School, JD (1995)
    • Member, Tulane Law Review
  • Hobart and William Smith Colleges, BA, honors (1992)

Admissions

  • Texas
  • New York
  • District of Columbia
  • U.S. Supreme Court
  • U.S. Court of Appeals for the Second Circuit
  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Federal Circuit
  • U.S. Tax Court
  • U.S. District Court for the Southern District of Texas
  • U.S. District Court for the Southern District of New York
  • U.S. Court of Federal Claims

Clerkships

  • Judicial Clerk, The Honorable Nauman Scott, U.S. District Court for the Western District of Louisiana (1995 - 1996)
  • Attorney Advisor, The Honorable Maurice Foley, U.S. Tax Court (1997 - 1998)

Practice Areas

The bar rules of some states require that the standards for an attorney's inclusion in certain public accolades or recognitions be provided. When such accolades or recognitions are listed, a hyperlink is provided that leads to a description of the respective selection methodology.

  • The Best Lawyers in America® (2021–2024)
  • University of Texas School of Law, Outstanding Service and Achievement in Oil, Gas, and Energy Taxation (2023)
  • Houston’s Top Lawyers List, Houstonia magazine (2022)
  • Houston Volunteer Lawyers Program, Outstanding Pro Bono Achievement Award (2019)
  • New York State Courts, Access to Justice Pro Bono Award (2015)
  • American Bar Association Section on Taxation, Pro Bono Award (2003)
  • American Bar Association Section on Taxation, Nolan Fellowship (2007)
  • Houston Volunteer Lawyers Board of Directors (2020–present)
  • American College of Tax Counsel (2016–present)
  • Adjunct Professor, University of Houston Law Center (2000, 2005–2013; 2016–present)
    • Legal Research & Writing (2000)
    • Tax Research (2005–2013)
    • Tax Controversies (2008–2013; 2016–present)
  • Tax Court Calendar Call Program, Houston (2010–2013, 2016–present)
  • American Bar Association Section on Taxation 
    • Council (2017–2020)
    • Energy & Environmental Taxes Chair (2013–2017)
    • Court Procedure & Practice Chair (2011–2013)
    • Pro Bono Committee Chair (2009–2011)
  • Houston Bar Association Section on Taxation Council (2005–2013)
  • Adjunct Professor, Texas Southern University Law School, Tax Controversies (2011)
  • American Bar Association Presidential Task Force On Attorney-Client Privilege (2005–2010)