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Peter C. Rock

Adjunct Professor

Part-Time Faculty


Peter C. Rock is an Assistant Director in the Advance Pricing and Mutual Agreement Program within the Large Business and International Division of the IRS. He is responsible for transfer pricing and allocation cases arising within the U. S. Competent Authority program.

Mr. Rock has extensive and broad experience within the IRS and its Office of Chief Counsel. Prior to his current position, he was a Branch Chief with the Advance Pricing Program of the Office of Associate Chief Counsel (International); Team Leader with the Advance Pricing Program; and an attorney in the Large and Mid-Size Business Division Counsel, Small Business Self-Employed Division Counsel, and San Francisco District Counsel.


  • BS, Saint Mary's College of California
  • JD, McGeorge School of Law
  • LLM, Georgetown University Law Center