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Peter Lowy
Partner
1111 Bagby Street
Suite 2100
Houston, TX 77002
Pete is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers in a broad spectrum of industries on tax compliance issues, tax planning, and risk management. He regularly works with the U.S. Internal Revenue Service and the Texas Comptroller’s office.
During his career, Pete...
Pete is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers in a broad spectrum of industries on tax compliance issues, tax planning, and risk management. He regularly works with the U.S. Internal Revenue Service and the Texas Comptroller’s office.
During his career, Pete has been responsible for more than 200 tax cases, over 10 of which involved amounts in issue exceeding $100 million, and two exceeding $1 billion in issue. He has also served as lead attorney in structuring several complex transactions including a multibillion-dollar, cross-border deal in the energy sector.
Pete handles both federal taxes and SALT (state and local taxes). On the federal side, Pete has extensive experience with federal income taxes, federal excise taxes, federal tax credits, and federal employment taxes. He also handles virtually every type of state and local tax, with specialization in sales and use taxes, fuel excise taxes, franchise taxes, income taxes, severance taxes and property taxes. Pete serves as the Chair of the firm's State & Local Tax (SALT) Practice.
Dedicated throughout his career to pro bono work, Pete devotes substantial time each year to represent underprivileged taxpayers and is a leader in the field. Pete is a past chair of the ABA Tax Section's Pro Bono Committee and coordinates a pro bono program for the U.S. Tax Court. For his work with disadvantaged taxpayers, Mr. Lowy has received pro bono awards from the ABA Tax Section (2003), the New York State Courts (2015), and the Houston Volunteer Lawyers Program (2019).
Pete is also a former chair of the ABA Tax Section’s Energy Tax Committee and of the ABA Tax Section's Committee on Court Procedure & Practice. Pete also served on the Council for the American Bar Association Tax Section. Pete is an adjunct law professor at the University of Houston Law Center, where he teaches Tax Controversies, and is widely published on tax controversy-related subjects.
has been responsible for more than 200 tax cases, over 10 of which involved amounts in issue exceeding $100 million, and two exceeding $1 billion in issue. He has also served as lead attorney in structuring several complex transactions including a multibillion-dollar, cross-border deal in the energy sector.
Pete handles both federal taxes and SALT (state and local taxes). On the federal side, Pete has extensive experience with federal income taxes, federal excise taxes, federal tax credits, and federal employment taxes. He also handles virtually every type of state and local tax, with specialization in sales and use taxes, fuel excise taxes, franchise taxes, income taxes, severance taxes and property taxes. Pete serves as the Chair of the firm's State & Local Tax (SALT) Practice.
Dedicated throughout his career to pro bono work, Pete devotes substantial time each year to represent underprivileged taxpayers and is a leader in the field. Pete is a past chair of the ABA Tax Section's Pro Bono Committee and coordinates a pro bono program for the U.S. Tax Court. For his work with disadvantaged taxpayers, Mr. Lowy has received pro bono awards from the ABA Tax Section (2003), the New York State Courts (2015), and the Houston Volunteer Lawyers Program (2019).
Pete is also a former chair of the ABA Tax Section’s Energy Tax Committee and of the ABA Tax Section's Committee on Court Procedure & Practice. Pete also served on the Council for the American Bar Association Tax Section. Pete is an adjunct law professor at the University of Houston Law Center, where he teaches Tax Controversies, and is widely published on tax controversy-related subjects.
Experience
Publications
- Co-author, Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, 4th Ed., Tax Management Portfolio Series (2017)
- Author, Legal Authorities in U.S. Federal Tax Matters – Research & Interpretation, 3rd Ed., Tax Management Portfolio Series (2016)
Speaking Engagements
- Speaker, IRS Audit, Appeals and Litigation Update, Tax Executive Institute, Houston Chapter (2025)
- Panelist, Loper Bright and Beyond: Transforming Tax Controversy and Compliance, CCH Answer Connect (2024)
- 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
Publications
- Co-author, Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, 4th Ed., Tax Management Portfolio Series (2017)
- Author, Legal Authorities in U.S. Federal Tax Matters – Research & Interpretation, 3rd Ed., Tax Management Portfolio Series (2016)
Speaking Engagements
- Speaker, IRS Audit, Appeals and Litigation Update, Tax Executive Institute, Houston Chapter (2025)
- Panelist, Loper Bright and Beyond: Transforming Tax Controversy and Compliance, CCH Answer Connect (2024)
- 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)
Media
Events / Speaking Engagements
| Loper Bright and Beyond: Transforming Tax Controversy and Compliance, Speaker (Sept. 19, 2024) |
Recognitions
- The Best Lawyers in America® (2021–2025)
- 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)
Professional Activities
- 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)
Pete is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers in a broad spectrum of industries on tax compliance issues, tax planning, and risk management. He regularly works with the U.S. Internal Revenue Service and the Texas Comptroller’s office.
During his career, Pete... has been responsible for more than 200 tax cases, over 10 of which involved amounts in issue exceeding $100 million, and two exceeding $1 billion in issue. He has also served as lead attorney in structuring several complex transactions including a multibillion-dollar, cross-border deal in the energy sector.
Pete handles both federal taxes and SALT (state and local taxes). On the federal side, Pete has extensive experience with federal income taxes, federal excise taxes, federal tax credits, and federal employment taxes. He also handles virtually every type of state and local tax, with specialization in sales and use taxes, fuel excise taxes, franchise taxes, income taxes, severance taxes and property taxes. Pete serves as the Chair of the firm's State & Local Tax (SALT) Practice.
Dedicated throughout his career to pro bono work, Pete devotes substantial time each year to represent underprivileged taxpayers and is a leader in the field. Pete is a past chair of the ABA Tax Section's Pro Bono Committee and coordinates a pro bono program for the U.S. Tax Court. For his work with disadvantaged taxpayers, Mr. Lowy has received pro bono awards from the ABA Tax Section (2003), the New York State Courts (2015), and the Houston Volunteer Lawyers Program (2019).
Pete is also a former chair of the ABA Tax Section’s Energy Tax Committee and of the ABA Tax Section's Committee on Court Procedure & Practice. Pete also served on the Council for the American Bar Association Tax Section. Pete is an adjunct law professor at the University of Houston Law Center, where he teaches Tax Controversies, and is widely published on tax controversy-related subjects.
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.Publications
- Co-author, Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, 4th Ed., Tax Management Portfolio Series (2017)
- Author, Legal Authorities in U.S. Federal Tax Matters – Research & Interpretation, 3rd Ed., Tax Management Portfolio Series (2016)
Speaking Engagements
- Speaker, IRS Audit, Appeals and Litigation Update, Tax Executive Institute, Houston Chapter (2025)
- Panelist, Loper Bright and Beyond: Transforming Tax Controversy and Compliance, CCH Answer Connect (2024)
- 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
Events /
Speaking Engagements
Speaking Engagements
| Loper Bright and Beyond: Transforming Tax Controversy and Compliance, Speaker (Sept. 19, 2024) |
- The Best Lawyers in America® (2021–2025)
- 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)
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