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Keri Brown
Keri D. Brown
Partner

Overview

"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.

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 - <em>The Houston Lawyer</em>, 2008-2014; Editor in Chief, 2012-2013
  • Houston Bar Association - Co-Chair, LegalLine Committee, 2009-2012
  • Houston Bar Association - Co-Chair, Law &amp; the Media Committee, 2009-2010
  • Kids in Need of Defense - Houston Advisory Committee Member
  • J.D., South Texas College of Law 2006
    summa cum laude
    Valedictorian
    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

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))


October 2024 Speeches & Presentations Protecting Buy/Sell Agreements from IRS Attacks, ALI-CLE
September 2024 Speeches & Presentations Current Development in Estate and Gift Tax Audits
April 2024 Speeches & Presentations Fiduciary Litigation Roundtable
June 2023 Speeches & Presentations Interactions with the IRS
June 2023 Speeches & Presentations Estate and Gift Audit & Litigation Issues
June 2022 Speeches & Presentations Masterclass in Estate Administration - Part III
June 2022 Speeches & Presentations Triggers for the IRS
May 2022 Speeches & Presentations Annual Fiduciary Litigation Roundtable
April 2022 Speeches & Presentations What's Old is New Again - Tax Uncertainty in 2022
15 March 2022 Speeches & Presentations How to Pay When the Bill Comes Due - Estate Liquidity in 2022
October 2024 Speeches & Presentations Protecting Buy/Sell Agreements from IRS Attacks, ALI-CLE
September 2024 Speeches & Presentations Current Development in Estate and Gift Tax Audits
April 2024 Speeches & Presentations Fiduciary Litigation Roundtable

Awards and 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