Overview

John Horne is a Tax Controversy associate in Mayer Brown's Washington DC office.

John focuses his practice on tax disputes and transfer pricing matters. He represents taxpayers at all levels of federal tax controversy, including IRS audits, administrative appeals, competent authority, and litigation before the United States Tax Court. His experience includes controversies with advance pricing agreements, transfer pricing, and debt-equity characterization.

John received his JD magna cum laude from the University of Kentucky Law School where he was Order of the Coif. Prior to joining Mayer Brown, he served as law clerk and attorney advisor to Hon. Joseph R. Goeke of the United States Tax Court.

Highlights
Tax Controversy Team of the Year

Experience

  • Tribune Media Co., et al. v. Commissioner, T.C. Docket Nos. 20940-16 and 20941-16 (tax treatment of leveraged partnership transaction).
  • Cross Refined Coal, LLC v. Commissioner, T.C. Docket. No. 19502-17, Index No. 177 (U.S. Tax Ct. Aug. 29, 2019) (finding that refined coal production partnership was a bona fide partnership and that its partners were bona fide partners)
  • Eaton Corporation v. Commissioner of Internal Revenue, T.C. Memo. 2017-147 (finding that the IRS’s cancellation of Advance Pricing Agreements was an abuse of discretion).
  • Tyco Electronics Corp., et. al v. Commissioner of Internal Revenue, T.C. Docket Nos. 16651-13, 16652-13, 16653-13, 16654-13, 16655-13, 16656-13, 16657-13, 16658-13, 16659-13, 16660-13, 16661-13, 16662-13, 16663-13, 16664-13, and 19556-13 (debt-equity characterization).
  • United States v. Eaton Corporation, Nos. 1:13-mc-102, 1:13-mc-111, 1:13-mc-112 (N.D. Ohio 2014); 2:13-cv-01825 (W.D. Pa. 2014); 3:13-cv-01956 (D.P.R. 2014) (summons enforcement litigation).

Education

University of Kentucky College of Law, JD, magna cum laude
Order of the Coif

Certified Public Accountant (license inactive)

University of Kentucky, MS

University of Kentucky, BBA, cum laude

Admissions

  • District of Columbia
  • Kentucky