Practice Areas
Education
LL.M., New York University School of Law, 1997
J.D., Tulane University Law School, 1995; member of Tulane Law Review
B.A., Hobart and William Smith Colleges, 1992, with honors
Honors
Best Lawyers in America, 2021-2024
"Top Lawyer," Houstonia Magazine, 2022
Nolan Fellowship, American Bar Association, Section on Taxation, 2007
Pro Bono Award, American Bar Association, Section on Taxation, 2003
Outstanding Pro Bono Achievement Award, Houston Volunteer Lawyers Program, 2019
Access to Justice Award, New York State Courts, 2015
Bar Admissions
Texas (since 2003)
New York (since 1996)
District of Columbia (since 2014)
Court Admissions
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 New York
U.S. District Court for the Southern District of Texas
U.S. Court of Federal Claims
Clerkships
Judicial Clerk, The Honorable Nauman Scott, U.S. District Court, Western District of Louisiana, 1995-1996
Attorney Advisor, The Honorable Maurice Foley, U.S. Tax Court, Washington, D.C., 1997-1998
Profile
Peter A. Lowy, a shareholder in Chamberlain Hrdlicka’s Houston office, 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 Internal Revenue Service and the Texas Comptroller’s office on a wide range of matters. Mr. Lowy also co-chairs Chamberlain Hrdlicka’s state and local tax practice.
During his career, Mr. Lowy has been responsible for over 200 tax cases that have cut across many types of taxes. This includes U.S. federal income, excise & employment taxes. It also includes the following state and local taxes (SALT): income, franchise, sales & use, severance, motor fuels, and property taxes. Disputes Mr. Lowy has participated in include over ten 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 multi-billion dollar, cross-border deal in the energy sector.
Dedicated throughout his career to pro bono work, Mr. Lowy devotes substantial time each year to represent underprivileged taxpayers. A leader in the pro bono field, Mr. Lowy 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).
Mr. Lowy is also a former chair of the American Bar Association Tax Section’s Energy Tax Committee and of the American Bar Association Tax Section's Committee on Court Procedure & Practice. Mr. Lowy also served on the Council for the American Bar Association Tax Section. Mr. Lowy is an adjunct law professor at the University of Houston Law Center, where he teaches Tax Controversies, and is widely published on tax audits and litigation-related subjects.
Mr. Lowy earned his LLM in Taxation from New York University School of Law, and his JD from Tulane Law School. Following law school, he clerked for a United States District Court and served as an attorney-advisor to the United States Tax Court.
Selected Speaking Engagements
- Panelist, State & Local Tax Hot Topics, Chamberlain Hrdlicka Virtual Tax Forum, November 2, 2021
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Panelist, Trying to Reach the Promised Land (Tips for Successful Refund Claims), LITC Grantee Conference Sponsored by Internal Revenue Service, December 17, 2020
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Speaker, SALT & the New Property Tax Relief Act, Houston CPA Society Expo, January 6, 2020
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Moderator, Changes & Developments in IRS Examination and Appeals, 15th Biennial Parker Fielder Oil & Gas Tax Conference, November 22, 2019
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Panelist, Winning Valuation Cases, Tax Executive Institute, Houston Chapter, 2019 Tax School, February 21, 2019
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Speaker, The U. S. Supreme Court’s Decision in South Dakota v. Wayfair and Its Impact on Texas Tax Law Issues, Chamberlain Hrdlicka San Antonio Tax and Business Planning Seminar, November 28, 2018
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Speaker, Judicial Highlights, Chamberlain Hrdlicka Houston Tax Forum, October 30, 2018
- Speaker, Best Practices for Resolving Federal and State Tax Controversies, Houston Chapter, Monthly Luncheon, June 6, 2018
- Speaker, Avoiding Ethical Pitfalls When Handling Tax Controversies, Houston Bar Association, Monthly Luncheon, March 21, 2018
- Panelist, Witness Preparation, Tax Executive Institute, Houston Chapter, 2018 Tax School, February 27, 2018
- Speaker, State and Local Tax Update, Houston CPA Society Expo, January 8, 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, November 17, 2017
- Speaker, Tackling Texas Taxes, Tax Executive Institute, Houston Chapter, Monthly Luncheon, August 17, 2017
- Speaker, Crash Course in Texas Taxes, Chamberlain Hrdlicka Tax Forum, November 3, 2016
- Panelist, Strategies for Closing Open Years: Audit and Litigation, Tax Executive Institute Roundtable, June 18, 2015
- Panelist, Cross Border Attorney - Client Privilege Issues, American Bar Association, Tax Section Meeting, May 8, 2015
- Panelist, Transfer Pricing Update, American Petroleum Institute 81st Federal Tax Forum, April, 28, 2015
- Chair, Energy & Environmental Taxes, American Bar Association, Tax Section Meeting, January 30, 2015
- Panelist, Cross Border Tax Issues in Oil & Gas, Texas Federal Tax Institute, Oil & Gas Tax Conference, November 3, 2014
- Chair, Energy & Environmental Taxes Committee, American Bar Association, Tax Section Meeting, September 19, 2014
- Panelist, U.S. State Tax Considerations for International Tax Reform, Tax Analysts, June 18, 2014
- Speaker, Global Tax Planning & Audit Defense Strategies in the Changing World of Intangibles, Tax Executive Institute, May 9, 2014
- Chair, Energy and Environmental Taxes, American Bar Association, Tax Section Meeting, May 9, 2014
- Moderator, Litigating Cross-Border Transactions in U.S. Courts, American Bar Association, Tax Section Meeting, May 9, 2014
- Speaker, OECD BEPS Update, American Petroleum Institute 80th Federal Tax Forum, April 28, 2014
- Moderator, Hot Topics In the Energy Industry, American Bar Association, Tax Section Meeting, January 24, 2014
- Moderator, Transfer Pricing in the Oil and Gas Industry: Exploring Key Issues from Concept through Implementation, 12th Biennial Parker Fielder Oil & Gas Tax Conference, November 21, 2013
- Speaker, Hot Topics in Tax Enforcement, 24th Annual Philadelphia Tax Conference, November 6, 2013
- Speaker, From the Experts: Tax Controversy and Tax Litigation Update, 72nd NYU Institute on Federal Taxation, October 20, 2013
- Speaker, Managing Risk in a New Era of International Tax Enforcement, Tax Executive Institute, Houston Chapter, Monthly Luncheon, October 17, 2013
- Moderator, Competent Authority: What Happens When More Than One State Wants to Tax the Same Income or Transaction?, California Tax Policy Conference, November 4, 2011
- Moderator, Comparing U.S. & Canada Approaches to Unrepresented Taxpayer Issues, American Bar Association, Tax Section Meeting, September 23, 2010
- Moderator, Strategies for Resolving International Tax Disputes, International Tax Forum, September 1, 2010
- Moderator, Transfer Pricing Litigation, American Bar Association, Tax Section Meeting, January 21, 2010
- Moderator, Getting to Yes – Dealing with IRS Cradle to Grave, 10th Biennial Parker Fielder Oil & Gas Tax Conference, October 29, 2009
- Moderator, Settling Tax Cases, American Bar Association, Tax Section Meeting, May 9, 2008
Selected Publications
- Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, 4th Ed., TAX MANAGEMENT PORTFOLIO SERIES (2017) (co-author)
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Legal Authorities in U.S. Federal Tax Matters – Research & Interpretation, 3rd Ed., TAX MANAGEMENT PORTFOLIO SERIES (2016)
- U.S. Federal Tax Research, 2nd Ed., TAX MANAGEMENT PORTFOLIO SERIES (2014)
- Effectively Representing Your Client Before the IRS, 5th Edition, American Bar Association Tax Section (2011) (contributing editor)
Professional Affiliations
- 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)
- Adjunct Professor, Texas Southern University Law School - Tax Controversies (2011)
- Chair, Court Procedure & Practice, American Bar Association Section on Taxation (2011-2013)
- Chair, Pro Bono Committee, American Bar Association Section on Taxation (2009-2011)
- Chair, Energy & Environmental Taxes, American Bar Association Section on Taxation (2013-2017)
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Council, American Bar Association Section of Taxation (2017-2020)
- Council, American Bar Association Presidential Task Force On Attorney-Client Privilege (2005-2010)
- Council, Houston Bar Association Section on Taxation (2005-2013)
- Recipient, Pro Bono Award from the American Bar Association Section on Taxation (2003)
- Recipient, Nolan Fellowship from the American Bar Association Section on Taxation (2007)
- Recipient, Access to Justice Pro Bono Award, New York State Courts (2015)
- Lead/Coordinator, Tax Court Calendar Call Program in Houston (2010-2013, 2016-present)
- Member, American College of Tax Counsel (2016-present)
- Board of Directors, Houston Volunteer Lawyers (2020-present)
News
News
- Best Lawyers in America® recognizes 87 Chamberlain Hrdlicka attorneys in a peer selection process for the 2024 edition of Best Lawyers in AmericaAugust 17, 2023
- Houstonia names 30 Chamberlain Hrdlicka attorneys as 2022 Top LawyersNovember 30, 2022
- Chamberlain Hrdlicka Reception Hall debuts at University of Houston Law CenterSeptember 21, 2022
- Best Lawyers in America® recognizes 72 Chamberlain Hrdlicka attorneys in a peer selection process for the 2023 edition of Best Lawyers in AmericaAugust 18, 2022
- Pete Lowy quoted in article on "Supreme Court SALT Cap Rejection Propels State Workarounds"Bloomberg, April 19, 2022
- Peter Lowy quoted in article on "New York’s SALT Cap Challenge Rejected by Supreme Court"Bloomberg, April 18, 2022
- Chamberlain Hrdlicka represents client in 5th Circuit Court of Appeals decision finding federal tax on crude oil exports is unconstitutionalMarch 25, 2022
- Peter Lowy quoted in article on "Rapid Response Required From Fuel Mixer, DOJ on Alternative Fuel"Tax Notes, February 14, 2022
- Chamberlain Hrdlicka's 43rd Annual Tax and Business Planning Seminar is virtual on November 2-4, 2021. Register to participate.November 2, 2021
- Best Lawyers in America® selects 54 Chamberlain Hrdlicka Attorneys for Recognition for 2022August 19, 2021
- Quote by Pete Lowy in “Circuit Court Shuns Butane Additive in Fuel Mixture Credit Case”Tax Notes, July 1, 2021
- Chamberlain Hrdlicka attorneys are ranked in Appellate, Commercial Litigation, Construction, Corporate, Criminal Defense, Employee Benefits, Energy, Immigration, Insurance, Intellectual Property, Labor & Employment, Real Estate, Tax, and Trust & EJune 22, 2021
- Quote by Peter Lowy in article on "Eighth Circuit Reverses Tax Court in Coffey, Again"Tax Notes, February 16, 2021
- Peter Lowy quoted in article on "IRS Lands Another Victory in Fuel Mixture Credit Case"Tax Notes, January 27, 2021
- Court orders $4.2 Million Tax Refund and Statutory Interest in Landmark DecisionJanuary 11, 2021
- Quote by Pete Lowy about Eighth Circuit reversing a Tax Court DecisionTax Notes, December 16, 2020
- Tax Notes quote by Pete Lowy on "Energy Companies Continue Battling IRS on Tax Credit Issues"October 26, 2020
- Tax Notes, September 25, 2020
- Chamberlain Hrdlicka team works on landmark case involving federal tax on crude oil exportsSeptember 24, 2020
- Tax Notes Federal, September 7, 2020
- Tax Update - Payroll Tax Deferral Starting September 1August 31, 2020
- Chamberlain Hrdlicka Attorneys Named to US News – 2021 Best Lawyers in America®, Three Attorneys Recognized as Lawyer of the YearAugust 20, 2020
- Peter Lowy quoted in "Supreme Court Throws IRS a Disgorgement Deduction Knuckleball"Tax Notes, July 2, 2020
- Chamberlain Shareholder Peter Lowy Appointed to Houston Volunteer Lawyers Board of DirectorsJune 8, 2020
- Chamberlain Hrdlicka Tax Alert - Paycheck Protection Program (PPP) Loan Forgiveness Tax IssuesMay 21, 2020
Presentations
Seminars & Presentations
- Jennifer Karpchuk & Pete Lowy to present Chamberlain Hrdlicka 2023 Midyear SALT UpdateVirtual Webinar, June 13, 2023
- 43rd Annual Tax and Business Planning Virtual Seminar is on November 2-4, 2021November 4, 2021
- Wyndham San Antonio Riverwalk, November 28, 2018
- Houston Marriott Westchase, October 30, 2018
- Crash Course in Texas TaxesMay 25, 2016
- Crash Course in Texas TaxesJuniper Room, May 11, 2016
Publications
Publications
- Pete Lowy article on “How to Contest Your Property Taxes Deep in the Heart of Texas”Bloomberg Tax, May 4, 2022
- Article by Pete Lowy and Alissa Gipson on "Fantasy Sports Cos. Should Plan Tax Defense After IRS Memo"Law360, August 27, 2020
- Article by Pete Lowy and Alissa Gipson on "New IRS Regs May Quash Popular SALT Cap Workaround"Law360, August 12, 2020
- Article by Pete Lowy, Juan Vasquez, and Morgan Alleyn on "High Court's SEC Enforcement Ruling has Tax Consequences"Law360 Tax Authority, June 26, 2020
- Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, 4th Ed., TAX MANAGEMENT PORTFOLIO SERIES (2017) (co-author)
-
Legal Authorities in U.S. Federal Tax Matters – Research & Interpretation, 3rd Ed., TAX MANAGEMENT PORTFOLIO SERIES (2016)
- U.S. Federal Tax Research, 2nd Ed., TAX MANAGEMENT PORTFOLIO SERIES (2014)
- Effectively Representing Your Client Before the IRS, 5th Edition, American Bar Association Tax Section (2011) (contributing editor)