Stephanie Loomis-Price

Shareholder; Co-Chair, Fiduciary Litigation
Houston
1100 JPMorgan Chase Tower
600 Travis Street
Houston, Texas 77002
713.650.2750 Direct
713.650.2600 Fax
sloomisprice@winstead.com
The Woodlands (secondary office)
24 Waterway Avenue
Suite 500
The Woodlands, Texas 77380
713.650.2750 Direct
713.650.2600 Fax
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Profile

Stephanie Loomis-Price handles federal gift and estate tax litigation against the Internal Revenue Service, as well as state fiduciary and probate controversy work. She has assisted clients in numerous cases in the United States Tax Court, the United States Court of Federal Claims, and the United States Court of Appeals for the Fifth, Eighth, and Eleventh Circuits, as well as County Probate Courts across Texas. She also counsels clients regarding complex estate administration. Stephanie currently serves as Assistant Finance Officer for the Real Property, Trusts and Estates Law Section of the American Bar Association, as well as Co-Chair of the Continuing Legal Education Committee and Co-Vice Chair of the Income and Transfer Tax Planning Group of the same organization. 

Board Certified in Estate Planning and Probate Law, Stephanie is a Fellow of the American College of Trust and Estate Counsel.

While her cases have included numerous challenging fiduciary litigation matters involving trustees, beneficiaries and grantors, her involvement in such litigation has increased markedly in recent years. That experience has mirrored similar involvement from several colleagues within the firm, resulting in the firm's formation of the Fiduciary Litigation Practice Group of which Stephanie serves as the Co-Chair to coalesce and capitalize on the impressive experience of Winstead attorneys in this burgeoning area of practice.

Prior to entering private practice, Stephanie served as a law clerk to the Honorable Lawrence S. Margolis of the United States Court of Federal Claims in Washington, D.C.

Representative Experience

In matters regarding increased gift tax asserted by Internal Revenue Service:

  • Estate of Anne Y. Petter – assisted in successful defense of taxpayer in case of first impression involving gift/sale of LLC units to family and charity made by way of dollar-based formula values “as finally determined for federal gift tax purposes” – Estate of Petter v. Comm’r, 98 T.C.M. (CCH) 534 (2009), aff’d, 653 F.3d 1012 (9th Cir. 2011); 
  • John H. and Karolyn M. Hendrix – assisted in successful defense of taxpayer in case regarding tax effect of gift of corporate stock made by way of dollar-based defined value formula – Hendrix v. Comm’r, 101 T.C.M. (CCH) 1642 (2011);
  • Tom and Kim Holman – successful defense of taxpayers in gift tax case involving IRS assertion of step transaction/indirect gift – Holman v. Comm'r, 130 T.C. 170 (2008);
  • Charles T. McCord, Jr., and Mary S. McCord – successful defense of taxpayers in case of first impression regarding tax effect of gifts of limited partnership interests made by way of dollar-based defined value formula – Succession of McCord, et al. v. Comm'r, 461 F.3d 614 (5th Cir. 2006);
  • Baine P. and Mildred Kerr – assisted in successful defense of taxpayers in Fifth Circuit appeal of case of first impression where IRS attempted to apply I.R.C. § 2074(b) in valuing interest in family limited partnership for gift tax purposes (Kerr v. Comm’r, 292 F.3d 490 (5th Cir. 2002)).

In matters regarding increased estate tax asserted by Internal Revenue Service:

  • Estate of Joseph R. Coulter – assisted in successful defense of estate against IRS assertion of $113 million estate tax deficiency involving first-time application of I.R.C. § 2036(b) (T.C. Docket No. 17458-99);
  • Estate of Jimmie T. Drewry – assisted in successful representation against IRS assertion of $30 million estate tax deficiency involving recognition of private annuities and value of interests in limited partnership owning broadcast properties (T.C. Docket No. 10328-00);
  • Estate of Samuel P. Black, Jr. – assisted in successful defense of estate against IRS attempt to apply I.R.C. § 2036 to ignore family limited partnership for estate tax purposes – Estate of Black, et al. v. Comm'r, 133 T.C. 15 (2009);
  • Estate of Wayne C. Bongard – successful defense of estate against IRS where IRS sought to apply I.R.C. § 2036 to ignore existence of limited liability company for estate tax purposes – Estate of Bongard v. Comm'r, 124 T.C. 95 (2005);
  • Estates of Eugene and Allene R. Stone – successful defense of estate against IRS where IRS sought to apply I.R.C. § 2036 to ignore existence of five family limited partnerships – Estate of Stone, et al. v. Comm'r, 86 T.C.M. (CCH) 551 (2003);
  • Estate of Beatrice Dunn – successful Fifth Circuit appeal and reversal of Tax Court decision regarding valuation of closely held corporation – Estate of Dunn v. Comm'r, 301 F.3d 339 (5th Cir. 2002);
  • Estate of Helen Bolton Jameson – successful representation in Fifth Circuit appeal involving unrealized capital gains discount when valuing stock in closely held C corporation – Estate of Jameson v. Comm'r, 267 F.3d 366 (5th Cir. 2001).

In matters regarding attorney-client and related privileges:

  • Estate of Nellie Segerstrom – successful representation of estate in federal district court in response to IRS summons of attorney-client privileged documents, and defense of estate in Tax Court in $18 million dispute with IRS regarding estate tax value of real estate partnerships – Estate of Segerstrom v. United States, 87 A.F.T.R.2d 2001-1153 (N.D. Cal. 2001).
Industries
    Bar Admissions
    • Texas, 1998
    • U.S. Tax Court
    • U.S. Court of Federal Claims
    • U.S. District Court, Southern District of Texas
    • U.S. Courts of Appeals for the Fifth, Eighth and Eleventh Circuits
    Languages
    Education
    Georgetown University Law Center
    • J.D., 1998
    • cum laude
    • Managing Editor, Georgetown Journal of Legal Ethics
    Johns Hopkins University
    • M.S., Applied Behavioral Science, 1996
    Austin College
    • B.A., International Studies and Spanish, 1989
    • with honors
    Professional & Community Involvement
    • Fellow, American College of Trust and Estate Counsel
    • Member, Long-Range Planning Committee, American College of Trust and Estate Counsel
    • Member, New Fellows Steering Committee, American College of Trust and Estate Counsetl
    • Executive Committee Member, American Bar Association (ABA) Real Property, Trust & Estate Law Section
    • Co-Chair, Continuing Legal Education Committee, ABA Real Property, Trust & Estate Law Section
    • Co-Vice Chair, Income & Transfer Tax Planning Group, ABA Real Property, Trust & Estate Law Section
    • Advisory Board Member, Skills Training for Estate Planners Program, ABA Real Property, Trust & Estate Law Section
    • Advisor on Estate Planning, Program Committee of ALI-CLE
    • Advisory Board Member, BNA Tax Management Estates, Gifts and Trusts Journal
    • Member, Houston Business & Estate Planning Council
    Awards & Recognition
    • Board Certified in Estate Planning and Probate Law, Texas Board of Legal Specialization
    • Best Lawyers in America, 2010-2014
    • Texas Super Lawyer, Texas Monthly, 2010-2013
    • Top Attorneys in Texas, Texas Monthly, 2011
    • 2009 Judge Thomas Gibbs Gee Award for Outstanding Pro Bono Service
    • 2008 Excellence in Writing Award, Probate & Property
    • Texas Rising Star, Texas Monthly, 2006
    Presentation Topics