Overview

Anthony Pastore is a Tax Controversy associate in Mayer Brown’s Chicago office. Since joining the firm in 2013, Anthony has represented corporate, partnership, and individual taxpayers in all stages of federal tax controversy, including examination, administrative appeals, and litigation in the United States Tax Court. His experience includes significant corporate matters involving section 482 allocations, debt-equity characterization, valuations, substance-over-form arguments, and penalties.

Anthony received his JD with honors from the University of Chicago Law School.

Highlights
Tax Controversy Team of the Year

Experience

  • Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5501-12 (IRC § 482 reallocations).
  • Cardiac Pacemakers, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 5502-12 (IRC § 482 reallocations).
  • Boston Scientific Corporation v. Commissioner of Internal Revenue, T.C. Docket No. 26876-11 (IRC § 482 reallocations).
  • Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5989-11 (IRC § 482 reallocations).
  • Cardiac Pacemakers, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 5990-11 (IRC § 482 reallocations).
  • Cardiac Pacemakers, Inc. v Commissioner of Internal Revenue, T.C. Docket No. 10985-11 (IRC § 367 allocations).
  • Tyco Electronics Corp., as successor in interest to Tycom Simplex Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16651-13 (debt-equity characterization).
  • Covidien LP, f.k.a. Tyco Healthcare Group, LP, Covidien Holding Inc., f.k.a. SWD Holding, Inc. I, Tax Matters Partner v. Commissioner of Internal Revenue, T.C. Docket No. 16663-13 (debt-equity characterization).
  • ADT Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 19556-13 (debt-equity characterization).
  • Tyco Electronics Corp., formerly known as AMP, Inc., & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16654-13 (debt-equity characterization).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16661-13 (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tyco International (PA), Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16659-13 (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to TSSL Holding Corp. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16655-13 (debt-equity characterization).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco (US) Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16658-13 (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tycom (US) Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16662-13 (debt-equity characterization).
  • United States Surgical Corporate & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16664-13 (debt-equity characterization).
  • ADT Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16656-13 (withholding tax).
  • Sherwood Medical Company I v. Commissioner of Internal Revenue, T.C. Docket No. 16652-13 (withholding tax).
  • Covidien Group S.A.R.L., f/k/a Tyco Group S.A.R.L. v. Commissioner of Internal Revenue, T.C. Docket No. 16653-13 (IRC § 881).
  • Tyco Electronics Corp., as successor in interest to Tyco International (PA), Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16657-13 (withholding tax).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco (US) Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16660-13 (withholding tax).

Education

The University of Chicago Law School, JD, with honors, Topics and Submissions Editor, Chicago Journal of International Law

Cornell University, BA, summa cum laude, Phi Beta Kappa

Admissions

  • Illinois

Court

  • US Tax Court
  • US District Court for the Central District of Illinois