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Alan I. Horowitz

Alan Horowitz’s practice focuses on appellate litigation, with particular experience in federal tax appeals. Although he practices primarily in the United States Supreme Court and federal courts of appeals, he also represents clients in litigation of legal issues in trial court. Mr. Horowitz has been described by clients quoted in Chambers as being "a go-to guy in appeals" who is "very good at taking complex tax issues and simplifying them." More >

Representative Engagements|View All

  • PPL v. Comm'r, 133 S. Ct. 1897 (2013), rev'g, 665 F.3d 60 (3d Cir. 2011) We filed amicus briefs on behalf of American Electric Power Co. in both the Third Circuit and the Supreme Court on the question of the foreign tax creditability of a United Kingdom tax. The Supreme Court ruled 9-0 in accordance with our position in favor of the taxpayer.
     
  • Exxon Mobil Corp. v. Comm'r, 689 F.3d 191 (2d Cir. 2012) The Second Circuit upheld the taxpayer's claim for interest netting notwithstanding directly contrary precedent in the Federal Circuit. 
     
  • DeNaples v. Comm'r, 674 F.3d 172 (3d Cir. 2012) The Third Circuit reversed the Tax Court and upheld the taxpayer's claim that certain interest income was tax exempt under Code section 103.
     
  • COSVI v. FAC, 563 F.3d 1 (1st Cir. 2009) The district court imposed a sanctions award under its inherent power. We were then engaged to handle the appeal, and the First Circuit reversed and vacated the sanctions order.
     
  • Robinson v. United States, 335 F.3d 1365 (Fed. Cir. 2003), cert. denied, 540 U.S. 1105 (2004) We represented the controlling shareholder of a film company and persuaded the Federal Circuit to reverse an unfavorable decision on an important executive compensation issue. The government then sought Supreme Court review, and we persuaded the Court to deny the government's petition for certiorari.
Government Experience
  • Assistant to the Solicitor General, U.S. Department of Justice, 1979 - 1986
  • Tax Assistant to the Solicitor General, U.S. Department of Justice, 1986 - 1990
Corporate Experience
Rankings and Recognition
  • Chambers USA: Tax Controversy (National), 2007 - 2016
  • International Tax Review: Tax Controversy Leaders (U.S.), 2015
  • The Best Lawyers in America®: Litigation & Controversy - Tax, 2013 - 2017
  • Legal 500: Tax: Tax Controversy, 2008, 2010 - 2011
Professional and Community Involvement
Bar Admissions
  • District of Columbia
Court Admissions
  • United States Supreme Court
  • United States Tax Court
  • United States Court of Appeals for the First Circuit
  • United States Court of Appeals for the Second Circuit
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Fourth Circuit
  • United States Court of Appeals for the Fifth Circuit
  • United States Court of Appeals for the Sixth Circuit
  • United States Court of Appeals for the Seventh Circuit
  • United States Court of Appeals for the Ninth Circuit
  • United States Court of Appeals for the Tenth Circuit
  • United States Court of Appeals for the Federal Circuit
  • United States Court of Appeals for the District of Columbia Circuit
  • United States Court of Federal Claims
Clerkships
Foreign Languages
  • Hebrew
Education
  • J.D., Columbia University School of Law, 1977
  • S.B., Massachusetts Institute of Technology, 1974