Kathy Pakenham

(IRS Audit) – Representing private equity portfolio company in audit of disguised sale issues arising from partnership acquisition

(IRS Audit) – Represent multinational conglomerate in examination of partnership basis items (ongoing)

(IRS Appeals) – Representing global distributor in transfer pricing dispute, resulting in more than 95% IRS concession

(U.S. Tax Ct.) – Lead trial counsel for supermajor oil and gas company in partnership tax issues arising from divestment of joint venture agreement

(N.D. Okla.); (10^th Cir.) – Representing a global oil and gas company on issues relating to construction of a closing agreement

(E.D. La.) – Representing integrated energy company on statute of limitations and equitable recoupment issues

(D. Idaho) – Obtained rare quashing of IRS summons based on violations of the Taxpayer Bill of Rights

(S.D. Ohio) – Successful summary judgment motion for a major national insurance company related to tax reserve computations, reversing negative TAM

(U.S. Tax Ct.) – Representing a global mining company in dispute with IRS over foreign tax credits and termination payment of a forward contract; resolved with no change

(IRS Audit) – Representing a major natural resources company in complex transfer pricing dispute with IRS; resolved with no change

(IRS Appeals) — Representing pharmaceutical company in proposed disallowance of research and development credits, resulting in 100% IRS concession

(IRS Audit) — Representing a multinational media company on audit related to cross-border hybrid transaction and foreign currency exchange issues, resulting in a 100% concession by the IRS and avoiding designation for litigation

(IRS Appeals) – Representing a global mining company on transfer pricing, IRC § 195 startup costs, and subsidiary expense issues

(U.S. Tax Ct.); (8^th Cir.) – Trial and appellate counsel in precedent setting case involving the interpretation of IRC § 274 and reversing adverse TAM for a national professional employer organization