"Keri Brown is building an excellent reputation in this market for her work on complex private wealth matters. 'She's absolutely brilliant,' says one source, and another says Brown is 'outstanding - she really has the skills for this work.'"
Chambers High Net Worth 2021
A trusted advisor to some of the nation's most prominent individuals, Keri Brown assists her clients on complex federal estate, gift and income tax litigation and controversy matters, including disputes and litigation with the Department of Justice and the Internal Revenue Service. She counsels high net worth individuals and families in a variety of courts, including in the United States Tax Court, United States District Courts and United States Courts of Appeals. She represents taxpayers in federal tax audits and administrative appeals, and represents fiduciaries and beneficiaries of trusts and estates in state courts with respect to administration and fiduciary duty issues. She also assists businesses and individuals in preparing for and navigating the litigation process in tax matters.
In 2021, Keri was recognized as a “Woman Who Means Business” by the Houston Business Journal for her significant business accomplishments, as well as her commitment to community service.
As firmwide Partner-in-Charge of Corporate Social Responsibility, Keri advances the firm’s commitment to its communities by allocating the firm’s people and financial resources to support communities, overseeing corporate citizenship, managing the firm’s pro bono efforts, and aligning the firm’s Corporate Social Responsibility efforts with those of its clients.
In 2020, Keri led a firmwide team of lawyers in creating a COVID-19 Community Resource Guide focused on the federal, state, and business response to the pandemic. Her work was featured in The American Lawyer, the Texas Lawbook, and The Houston Lawyer, and she was recognized by the Houston Chronicle as one of the “Heroes of the Front Line” in the battle against COVID-19. In the aftermath of Hurricane Harvey in 2017, Keri's pro bono efforts were featured in the Wall Street Journal, ABA Journal, Texas Bar Journal, Texas Lawyer, Houston Business Journal, and The Houston Lawyer. The State Bar of Texas honored Keri with its 2018 Pro Bono Coordinator Award.
Related Experience
- Estate of Anenberg – Unanimous Tax Court rejected IRS argument that termination of a QTIP trust was a gift under I.R.C. § 2519 (Estate of Anenberg v. Comm’r, 162 T.C. No. 9 (2024))
- McDougall – Following Anenberg, Tax Court held that termination of a QTIP trust was not a gift under I.R.C. § 2519, but did result in gifts from the children to the surviving spouse (McDougall v. Comm’r, 163 T.C. No. 5 (2024))
- Steinberg – Tax Court rejected IRS challenge to gift tax value offset for donees’ assumption of potential estate tax under I.R.C. § 2035 ("net, net gift") (Steinberg v. Comm’r, 141 T.C. 258 (2013))
- Estate of Anne Y. Petter – successful defense of taxpayer in case of first impression involving gift/sale of LLC units to family and charity using a dollar value formula based on values as “finally determined for federal gift tax purposes.” (Petter v. Comm’r, 98 T.C.M. (CCH) 534 (2009)), aff’d, 653 F.3d 1012 (9th Cir. 2011))
- Hendrix – successful defense of taxpayer in case regarding the tax effect of a gift of corporate stock made by way of a dollar-based defined value formula (Hendrix v. Comm’r, T.C. Memo 2011-133 (June 15, 2011))
- Estate of Helen Christiansen – successful Eighth Circuit affirmance of Tax Court decision in case of first impression regarding tax effect of partial disclaimer of limited partnership interest to charity made by way of formula based on values “as finally determined for estate tax purposes.” (Estate of Christiansen v. Comm’r, 586 F.3d 1061 (8th Cir. 2009))
- Estate of Charles H. Murphy, Jr. – successful $42 million estate tax refund suit involving numerous valuation issues and IRS attempt to ignore limited partnership under I.R.C. § 2036. (Estate of Murphy v. United States, No. 07-CV-1013, 2009 WL 3366099 (W.D. Ark. Oct. 2, 2009))
Awards & Community
Texas Bar Foundation's Terry Lee Grantham Memorial Award, 2022
Houston Bar Foundation's Award for "Outstanding Contribution to HVL by a Pro Bono Coordinator," 2021
Recognized in Private Wealth Law by Chambers High Net Worth, 2020, 2021, 2022, 2023 & 2024
Houston Business Journal's "Woman Who Means Business," 2021
State Bar of Texas Board of Directors resolution for exceptional service to the legal profession and community, 2020
Texas Appleseed's Pro Bono Leadership Award, 2019
Top Women Lawyers, 2021; Top 50 Women Lawyers, National Diversity Council, 2019
State Bar of Texas Pro Bono Coordinator Award, 2018
Houston Business Journal's "40 Under 40" Class of 2018
Houston Bar Foundation's Award for "Outstanding Contribution by an Individual" to the Houston Volunteer Lawyers, 2017
Recognized as a Texas Super Lawyer Rising Star, (Thomson Reuters), 2014, 2015, 2016, 2017 & 2018
Houston Bar Association President's Award, 2010, 2013
Noted in The Legal 500 U.S. for Tax Controversy, 2009-2012, 2019, 2023
Education
J.D., South Texas College of Law 2006summa cum laudeValedictorian
Order of the Lytae
Phi Delta Phi
Dean's List
Outstanding Female Graduate
Note & Comment Editor, South Texas Law Review
B.A., Speech Communication, Texas A&M University 2001
Admissions & Affiliations
State Bar of Texas
Fellow, American College of Trust and Estate Counsel
Board Certified in Estate Planning & Probate Law by the Texas Board of Legal Specialization
United States Courts of Appeals for the Fifth, Eighth, Ninth & Eleventh Circuits
United States Tax Court
American Bar Association - Real Property, Trust & Estate Section, Income & Transfer Tax Planning Group Chair, 2020-2022, Vice-Chair, 2018-2020; Tax Litigation & Controversy Committee Co-Chair, 2012-2016, Co-Vice Chair, 2010-2012
Life Fellow - Texas Bar Foundation
Sustaining Life Fellow - Houston Bar Foundation
Impact100, Founding Member
State Bar of Texas - Legal Services to the Poor in Civil Matters Committee, Chair, 2022-present; Member, 2019-2022
State Bar of Texas - Pro Bono Workgroup, 2020-present
Houston Volunteer Lawyers - Chair, 2021-2022; Chair-Elect & Executive Committee member, 2020-2021; Board Secretary & Development Committee Chair, 2019-2020, Member, 2018-2019
Texas Appleseed - Board of Directors, 2020-present
Houston Bar Association - Board of Directors, 2022-2024
Houston Bar Association - Houston Lawyer Referral Service, Board of Directors, 2022-present
Houston Bar Association - Probate, Trusts & Estates Section Council, 2018-present, Member, 2007-present
Houston Bar Association - Disaster Preparedness Committee Co-Chair, 2020-2021
Houston Bar Association - Fee Dispute Committee Co-Chair, 2019-2020, Member, 2018-2019
Houston Bar Association - CLE Committee, Elder Law Committee, 2015-2016
Houston Bar Association - Speakers Bureau, 2014-2015
Houston Bar Association - Habitat for Humanity Committee, Harris County Law Library Committee, 2013-2014
Houston Bar Association - The Houston Lawyer, 2008-2014; Editor in Chief, 2012-2013
Houston Bar Association - Co-Chair, LegalLine Committee, 2009-2012
Houston Bar Association - Co-Chair, Law & the Media Committee, 2009-2010
Kids in Need of Defense - Houston Advisory Committee Member