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Kevin L. Kenworthy

Kevin Kenworthy practices in the area of federal income taxation, with an emphasis on tax litigation and other tax controversy matters. Over his 25 plus years in practice, Mr. Kenworthy has represented large multinational clients in a variety of disputes involving billions of dollars before the courts and the Internal Revenue Service. He has led or has been a member of the successful litigating teams for some of the firm's most significant tax cases during this time. Mr. Kenworthy regularly produces extraordinary resolutions for his multinational clients in disputes with the IRS.

Mr. Kenworthy has represented clients in significant disputes ranging from transfer pricing to foreign tax credits, R&E credits, natural resource issues, interest disputes, and methods of accounting. In addition to his advocacy on a broad range of domestic and international tax issues, Mr. Kenworthy has deep subject matter experience in court practice and IRS administrative procedure.  More >

Representative Engagements|View All

  • Exxon Mobil Corp. v. Commissioner, 136 T.C. No. 5 (2011), aff'd 689 F.3d 191 (2d Cir. 2012) (whether taxpayer eligible for interest netting under section 6621(d)).
     
  • Howard Hughes Properties Inc. et al. v. Commissioner, Tax Court Dkt. 10565-11 (whether residential real estate developer permitted to use completed contract method of accounting)(trial November 2012).
     
  • Lockheed Martin Corp. v. United States, D. Md. Dkt. 8:12cv3725-DKC (issues involving R&E credit claimed for aerospace prototypes and the interaction between section 199 and the extraterritorial income exclusion)(pre-trial proceedings).
     
  • Estate of James B. Rehrig and Mary Y. Rehrig, et al. v. Commissioner, Tax Court Dkt. 10067-10 (whether stock held by owners of closely-held company was restricted stock for purposes of Treas. Reg. § 1.1361-1(b)(3))(settled before trial).
     
  • Represent U.S.-based multinational in a transfer pricing dispute related to the cross-border provision of services (settled at Appeals).
Government Experience
Corporate Experience
Rankings and Recognition
  • Washington, D.C. Super Lawyers®: Tax, 2013 - 2016
  • Chambers USA:  Tax Controversy (National), 2008 - 2016
  • Legal 500: Tax: Contentious, 2010 - 2012, 2014 - 2016 
  • Legal 500: Tax: International Tax, 2014 - 2016
  • International Tax Review: Tax Controversy Leaders (U.S.), 2014 - 2015
Professional and Community Involvement
  • Co-author, Tax Management Portfolio 891-2nd, Transfer Pricing: Audits, Appeals, and Penalties (BNA 2011)
  • Contributor, Transfer Pricing Answer Book (PLI 2012)
  • Former Chair, Court Procedure and Practice Committee, American Bar Association
  • Member, J. Edgar Murdock American Inn of Court
  • Member, Advisory Committee, Parker C. Fielder Oil and Gas Tax Conference
Bar Admissions
  • District of Columbia
  • Oklahoma
Court Admissions
  • United States Tax Court
  • United States Court of Federal Claims
  • United States District Court for the Northern District of Texas
  • United States District Court for the District of Columbia
  • United States Court of Appeals for the First, Second, Third, Fifth, and Sixth Circuits
  • United States Supreme Court
Clerkships
  • Clerk, The Honorable William A. Goffe, United States Tax Court
Foreign Languages
Education
  • J.D., Southern Methodist University School of Law, Order of the Coif, 1985
  • B.B.A. (Accounting), University of Oklahoma, with distinction, 1982