Associate
Sam Bear
Tax, Tax Controversy & Litigation, International Tax & Transfer Pricing
Overview
Sam Bear, an associate in the Chicago office, has represented clients in high-stakes tax controversies in examination, administrative appeals, litigation, trial, and appellate review. Her work encompasses issues related to transfer pricing, carrybacks of net operating losses, subpart F, interest netting, penalties, economic substance, sham-transaction, and similar substance-over-form doctrines.
Experience
- Anadarko Petroleum Corp., et al. v. Commissioner, T.C. Docket Nos. 23018-18 and 23019-18 (ongoing case challenging the IRS's determination that a settlement payment is not deductible).
- GSS Holdings (Liberty) Inc. v. United States, No. 1:19-cv-00728 (Federal Circuit) (ongoing case regarding the limitations on the IRS’s use of the step transaction doctrine).
- Represented a major bank in district court for a refund related to interest netting.
- Achieved a full concession and abatement of penalties in IRS Appeals under a reasonable cause defense.
- Secured a favorable settlement representing a large Internet company in a multimillion-dollar privacy claim.
Education
- Brown University, BA, with honors
- University of Michigan Law School, JD, cum laude
Admissions
- Illinois
Courts
- US Court of Appeals for the Federal Circuit
- US Tax Court
- US District Court for the Western District of North Carolina