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Pryor, Kevin R.

Kevin R. Pryor

Partner
  • Tax
  • Tax Controversy

Biography

KEVIN PRYOR focuses his practice on contested federal tax matters at the IRS examination level, at the IRS administrative appeals level, and in docketed litigation. He also has significant experience advising managers on the federal tax issues arising from the formation and operation of hedge funds, commodity pools, and private equity funds. Kevin taught as an Adjunct Professor in the Graduate Program in Taxation at IIT Chicago-Kent College of Law. He has been recommended in Legal 500 United States (2012–2014) and is recognized in The Best Lawyers of America (2026) for his work in Tax.

Experience

Representative Matters

Recent representative tax controversy matters include:

  • Representation of an insurance company in a U.S. Court of Federal Claims refund case arising from a series of structured transactions
  • Representation of a railroad before the IRS Appeals division involving the valuation of real estate that had been donated to local government
  • Representation of a hedge fund manager before the IRS Appeals division with respect to the deductibility of fees and expenses paid by the manager on behalf of the hedge fund
  • Representation of a publishing company in a U.S. Tax Court case concerning the qualification of software development expenses for the research credit
  • Representation of an agricultural company in a U.S. Tax Court case involving inventory accounting issues

Credentials

Admissions & Certifications
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • Illinois
Education
  • The University of Chicago Law School, J.D., 1997, with honors
  • Brigham Young University, B.A., 1994, magna cum laude

News & Insights

Recent Speaking Engagements

  • “Issues Discussion Forum – Up to the 30 Day Letter” Tax Executives Institute Audits and Appeals Seminar, New Orleans (April 30, 2018)
  • “Responding Effectively to IDRs,” Tax Executives Institute Audits and Appeals West Seminar, Seattle (May 1–2, 2017)
  • “Tax Research,” Tax Executives Institute Tax Research Seminar, Kansas City, Missouri (October 27, 2016)
  • “Tax Research,” Tax Executives Institute Tax Research Seminar, Fort Worth, Texas (October 26, 2016)
  • “Information Document Requests:  Framing the Issues and Preparing the Responses,” Tax Executives Institute Audits and Appeals Seminar, Santa Clara (May 17–19, 2016)
  • “Tax Research,” Tax Executives Institute Tax Research Seminar, Des Moines (May 17, 2016)
  • “Handling Tax Controversies,” Tax Executives Institute Seminar, Seattle (April 20, 2016)
  • “LB&I Issue-Based Examinations: The Road Ahead,” Tax Executives Institute National Audits and Appeals Seminar, Chicago (May 19–21, 2015)
  • “Tax Research,” Tax Executives Institute Tax Research Seminar, Omaha, Nebraska (April  29, 2015)
  • “Tax Practice and Procedure,” IIT Chicago-Kent College of Law, Tax L.L.M. Program, Chicago (Spring Semester 2014)
  • “Compliance and Audit Issues,” Executive Enterprise Institute International Tax Boot Camp, Chicago (June 18–19, 2013)
  • “IRS Administration and LB&I Update,” 32nd Annual Federal Tax Institute, Chicago (May 2–3, 2013)
  • “Tax Controversy,” Tax Executives Institute – Iowa Chapter, Des Moines (September 27, 2012)
  • “IRS Administration and LB&I Update,” 31st Annual Federal Tax Institute, Chicago (May 17–18, 2012)
  • “Sales and Exchanges,” IIT Chicago-Kent College of Law, Tax L.L.M. Program, Chicago (Fall Semesters 2002–2015)