18th Annual Tax Controversy Forum 2026 – Track I (Presented by NYU School of Professional Studies)

Caroline D. Ciraolo, Esq., Partner | Kostelanetz

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and as an independent mediator in tax-related administrative proceedings and litigation. During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys across 14 civil, criminal, and appellate sections.

• Education & Credentials

Caroline earned an LL.M. in Taxation from the University of Baltimore School of Law in 1994, a J.D. with Honors from the University of Maryland School of Law in 1993, and a B.S. in Finance with Honors, cum laude, from The College of New Jersey in 1990. She is admitted to practice in Maryland (1993), Pennsylvania (1995), New Jersey (1995), and the District of Columbia (1995). Her court admissions include the U.S. Tax Court; the U.S. District Court for the District of Maryland; the U.S. Court of Federal Claims; the U.S. Courts of Appeals for the Second, Fourth, Ninth, and Federal Circuits; and the U.S. Supreme Court.

• Recognition & Leadership

Caroline is recognized by Chambers for USA: Tax Fraud (Nationwide) (Band 1), Tax Controversy – Nationwide (Band 2), District of Columbia: Tax (Band 1), and High Net Worth: Tax-Private Client – USA (Band 1). She is named a Leading Lawyer by Legal 500 and is recognized by Benchmark Litigation, ITR World Tax (Tax Controversy, World Tax – Highly Regarded, and Women in Tax Leader), and Super Lawyers in both D.C. and Maryland (including Top 10 in Maryland and a Maryland cover story in 2013). She is recognized in Best Lawyers in America for Litigation and Controversy – Tax, Tax Law, and Criminal Defense: White Collar, and has been named Lawyer of the Year for Litigation and Controversy – Tax (D.C. 2022, 2024, and 2026; Maryland 2012) and for Tax Law (D.C. 2025). She received the Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014) and was named to The Daily Record’s Top 100 Women Circle of Excellence. She is also a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, the IRS Chief Counsel Award (the highest honor that office can confer), and the Tax Excellence Award from the Taxation Section of the Maryland State Bar Association.

• Professional Involvement

Caroline is former President of the American College of Tax Counsel and former Chair of the Civil & Criminal Tax Penalties Committee of the American Bar Association Section of Taxation. She served as the ABA Tax Section’s inaugural Vice Chair for Membership, Diversity, and Inclusion, and inaugural Chair of the Loretta Collins Argrett Fellowship Program. She is a Fellow of the American College of Tax Counsel (Immediate Past President 2021-2022, Vice President 2020-2021, Secretary/Treasurer 2018-2020, and Regent for the 4th Circuit 2017-2018) and a Fellow of the Litigation Counsel of America and the Maryland Bar Foundation. She also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade. She is an Adjunct Professor at the Georgetown University Law Center, teaching International Tax Controversies and Criminal Tax Law and Procedure, and previously taught Tax Practice and Procedure and Criminal Tax in the University of Baltimore School of Law Graduate Tax Program.

• Experience

Caroline served as Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division (February 25, 2015 – July 15, 2016), as well as Principal Deputy Assistant Attorney General (January 12, 2015 – January 20, 2017), Deputy Assistant Attorney General for Criminal Matters (October 5, 2015 – January 20, 2017), and Deputy Assistant Attorney General for Policy and Planning (January 12, 2015 – January 20, 2017). During her tenure, she was actively involved in all aspects of Tax Division operations and was responsible for approximately 500 employees, including more than 360 attorneys across 14 civil, criminal, and appellate sections. Earlier in her career, she served as Attorney Advisor to the Honorable Stanley J. Goldberg of the U.S. Tax Court (August 1994 – August 1996) in Washington, D.C. As a partner with Kostelanetz LLP and founder of its Washington, D.C. office, her practice focuses on federal and state civil tax controversies, sensitive audits, administrative appeals, litigation, internal investigations, and criminal tax investigations and prosecutions, and she serves as a consulting and testifying expert witness and independent mediator in tax-related matters.

 

Michael J. Desmond, Esq., Member and Tax Department Chair| Miller & Chevalier, Chartered

Michael J. Desmond is a Member at Miller & Chevalier, where he serves as Chair of the Tax practice and Practice Co-Lead of Tax Controversy & Litigation. His practice covers a broad range of federal tax matters with a focus on administrative tax policy, tax controversy, and litigation. He represents clients in approaches to the Internal Revenue Service (IRS) and the U.S. Department of the Treasury on administrative rulemaking matters and matters relating to tax administration and enforcement, seeking clarity on the application of federal tax laws. He also represents clients before the examination divisions of the IRS, the IRS Independent Office of Appeals, and in the U.S. Tax Court, federal district courts, the Court of Federal Claims, and federal courts of appeal. His clients have included businesses and individuals across a wide range of industries, including real estate, financial services, publishing, technology, medical services and devices, and entertainment. Clients quoted in Chambers USA have described him as “very smart, strategic, and knowledgeable of tax law,” “responsive and insightful,” noting that his knowledge of complex matters is incredibly valuable.

• Education & Credentials

Mike earned his J.D., magna cum laude, from The Catholic University of America, Columbus School of Law in 1994, where he served as Executive Editor of the Catholic University Law Review. He received his B.A. from the University of California, Santa Barbara in 1990. He is admitted to practice in California, the District of Columbia, and New York. His court admissions include the United States Tax Court; the U.S. Courts of Appeals for the Federal, Fourth, Seventh, Ninth, and Tenth Circuits; the U.S. District Courts for the District of Columbia, the Central District of California, and the Northern District of California; and the U.S. Court of Federal Claims.

• Recognition & Leadership

Mike has been recognized in The Best Lawyers in America® for Tax Law from 2012 through 2025 and was named Lawyer of the Year for Tax Litigation and Controversy in 2023. He is ranked in Chambers High Net Worth USA for Tax: Private Client (Nationwide) from 2023 through 2025 and in Chambers USA for Tax: Controversy (Nationwide) from 2008 through 2019 and 2023 through 2025. He is recognized by Legal 500 for Tax: U.S. Taxes: Contentious from 2008 through 2018 and 2022 through 2025, including Hall of Fame honors in 2024 and 2025, and was named to the Lawdragon: 500 Leading Global Tax Lawyers Guide in 2025. His government service was recognized with the IRS Commissioner’s Award (2008, 2021), the IRS Chief Counsel’s Award (2008), the Treasury Secretary’s Honor Award (2007), and the U.S. Department of Justice, Tax Division Award for Sustained Superior Performance (1998).

• Professional Involvement

Mike currently serves as President of the American College of Tax Counsel and as Vice Chair of Government Relations for the Tax Section of the American Bar Association. He is a former Chair of the Committee on Government Submissions, the Standards of Tax Practice Committee, and the Tax Shelters Committee within the ABA Tax Section, and he serves as a Trustee of the Southern Federal Tax Institute. He previously served as an adjunct professor at Georgetown University Law Center and has been a guest lecturer at law schools around the country.

• Experience

Prior to joining Miller & Chevalier, Mike was a partner with a global law firm. Before that, he served as the 48th Chief Counsel of the IRS, nominated by the president and confirmed by the Senate, where he was the principal legal officer for the IRS, overseeing a staff of nearly 1,500 lawyers responsible for interpreting and advising on all aspects of federal tax law. During his tenure, the Office issued more than 100 sets of proposed and final regulations implementing the Tax Cuts and Jobs Act of 2017 and published dozens of guidance items relating to the COVID-19 pandemic, while litigating nearly 25,000 cases pending in the U.S. Tax Court and working with the DOJ Tax Division on cases in other courts, including the U.S. Supreme Court. He previously served as Tax Legislative Counsel at the Treasury, the principal legal advisor to the Secretary and Assistant Secretary (Tax Policy) on all domestic aspects of federal tax law other than employee benefits, working closely with the congressional tax writing committees. Earlier in his career, he served as a Trial Attorney in the DOJ Tax Division, litigating dozens of cases throughout the western U.S., and as a law clerk to the Honorable Ronald S.W. Lew of the U.S. District Court for the Central District of California. In private practice, he has been counsel of record in numerous docketed tax matters, litigating many to published decision on issues including transferee liability, debt versus equity treatment of partnership investments, the “property for services” rules, partnership refund claim requirements, fraud penalties, and the valuation of customer-based intangibles.

 

Hon. Frank J. Bisignano, Chief Executive Officer | Internal Revenue Service

Hon Frank J. Bisignano is the first Chief Executive Officer of the Internal Revenue Service, managing an agency that collected approximately $5.1 trillion in tax revenue in Fiscal Year 2024 — revenue that consistently generates about 96% of the funding that supports the federal government’s operations each year. He brings to this role extensive leadership experience from several decades in the financial services sector. Widely recognized for his expertise in operational management and technology innovation, he has consistently driven growth, improved customer service, and led complex organizations through modernization and digital transformation. As IRS CEO, he works to advance the IRS mission by sharpening its focus on three priorities: improving collections, safeguarding privacy, and enhancing customer service — goals that guide how the agency delivers better outcomes for taxpayers and strengthening the IRS for the future.

• Recognition & Leadership

Mr. Bisignano is widely recognized for his expertise in operational management and technology innovation, and throughout his career he has consistently driven growth, improved customer service, and led complex organizations through modernization and digital transformation. He started his career on Wall Street and became the youngest Senior Vice President of Shearson Lehman/American Express at age 25. Following the September 11, 2001 attacks on New York’s World Trade Center, during which he was with Citigroup, he led the relocation of more than 16,000 displaced Citigroup employees and became a founding member and board leader of the 9/11 Memorial & Museum.

• Professional Involvement

Alongside his duties as IRS CEO, Mr. Bisignano continues to serve as the Commissioner of the Social Security Administration, a position he assumed in May 2025, where he has taken swift action to transform that agency into a premier service organization delivering best-in-class service to the American people. He also serves as a founding member and board leader of the 9/11 Memorial & Museum.

• Experience

Prior to his government service, Mr. Bisignano was CEO of Fiserv, the world’s largest financial services and payment technology company. Before Fiserv, he was the Chairman and CEO of First Data, where he transformed the 43-year-old company into a technology innovator, industry collaborator, and commerce enabler for the 21st century. He started his career on Wall Street and was the youngest Senior Vice President of Shearson Lehman/American Express at age 25. He later became the co-Chief Operating Officer for J.P. Morgan Chase and the CEO of its Mortgage Banking unit. He also held several roles at Citigroup, and was with Citigroup on September 11, 2001, when terrorists attacked New York’s World Trade Center; in the aftermath, he led the relocation of more than 16,000 displaced Citigroup employees.

 

Sharon Katz-Pearlman, Esq., Shareholder | Greenberg Traurig

Sharon Katz-Pearlman is a Shareholder at Greenberg Traurig, LLP, based in New York, who focuses her practice on the representation of large multinationals, partnerships, high-wealth individuals, and other taxpayers before the Internal Revenue Service (IRS) on both domestic and cross-border issues, across all industries. She represents clients from the pre-exam phase — including voluntary disclosures and pre-filing agreements — through examination, appeals, and into litigation if necessary, and has wide-ranging experience with resolution of transfer pricing issues at the examination and IRS Appeals level as well as with Competent Authority proceedings, seeking a Mutual Agreement Procedure (MAP) agreement and/or an Advanced Pricing Agreement (APA). In addition to traditional representation before the IRS, she represents clients using the full range of IRS Alternative Dispute Resolution tools, advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs, and advises clients on application to and participation in the OECD’s International Compliance Assurance Programme (ICAP) process. She is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that guides clients through tariff refund matters, tax, litigation, and M&A activity spurred by global shifts. Sharon brings over 30 years of experience in federal tax controversy, gained in both private and government practice.

• Sharon Katz-Pearlman

Sharon earned an LL.M. from New York University School of Law, a J.D., cum laude, from the Benjamin N. Cardozo School of Law, and a B.A., cum laude, from Barnard College, Columbia University. She is admitted to practice in New York and before the U.S. Tax Court.

• Recognition & Leadership

Sharon has been shortlisted by The Legal Benchmarking Group for its “Women in Business Awards,” including North America Transfer Pricing Lawyer of the Year (2026) and North America Tax Lawyer of the Year (2025). She is listed in The Best Lawyers in America for Tax Law (2025-2026) and in Lawdragon’s “500 Leading Global Tax Lawyers” (2025). She is recognized by International Tax Review as a “Controversy Leader” in its Comprehensive Guide to the World’s Leading Tax Controversy Advisors, in its Women in Tax Leaders Guide (2025-2026), and as a World Tax Leader, and is listed in Euromoney’s Expert Guides for “Women in Business Law.” While with the IRS Office of Chief Counsel, she earned the National Attorney of the Year Award, given annually to one attorney for outstanding contribution to the Office.

• Professional Involvement

Sharon is a Fellow of the American College of Tax Counsel and an Adjunct Professor of Law at NYU Law School, where she teaches Civil Tax Controversies & Litigation. She is a former member (four-year term) of the United Nations Tax Subcommittee on Dispute Avoidance, Resolution and the Mutual Agreement Process, under the direction of the United Nations Committee of International Tax Experts on International Cooperation in Tax Matters. She serves on the Board of Overseers of the Cardozo School of Law, Yeshiva University (2023-Present), and has served on the Law360 Tax Authority Federal Editorial Advisory Board (2024) and International Editorial Advisory Board (2023). She is a member of the National Association of Women Lawyers, the American Bar Association, the New York State Bar Association, and the Federal Bar Association. She is often quoted in tax publications such as Tax Notes and frequently speaks on tax controversy topics at industry conferences including the Tax Executives Institute (TEI), the American Bar Association (ABA), the Practicing Law Institute (PLI), the NYU Tax Controversy Forum, and the Tax Council Policy Institute (TCPI).

• Experience

Immediately prior to joining Greenberg Traurig, Sharon served as the national and global practice leader of the Tax Controversy & Dispute Resolution practice at a Big Four accounting firm. She was with KPMG, LLP from 1993 to 2022, where she held roles including Co-National Principal in Charge, Tax Controversy & Dispute Resolution, Washington National Tax; National Principal in Charge, Tax Controversy & Dispute Resolution; Northeast Area Principal in Charge, Tax Controversy Services; and Senior Manager, Tax Controversy Services. From 2008 to 2022, she served as Global Head of the Tax Dispute Resolution and Controversy Network at KPMG International. Earlier in her career, she was a litigator for the IRS Office of Chief Counsel from 1986 to 1993, serving as a Special Litigation Attorney (and recipient of the National Attorney of the Year Award in 1989) as well as a Trial Attorney/Senior Trial Attorney. She has served as an Adjunct Professor of Law in the LLM Program at New York University School of Law from 2017 to the present.

 

Lia Colbert, Commissioner, Small Business/Self-Employed Division | Internal Revenue Service

Amalia “Lia” Colbert serves as Commissioner of the Small Business/Self-Employed (SB/SE) Division of the Internal Revenue Service. In this role, she oversees taxpayer programs and services affecting the nation’s small business and self-employed individuals, providing oversight of SB/SE’s $2.34 billion budget and executive leadership to a staff of over 20,000 employees responsible for service and enforcement programs for 57 million taxpayers who file personal, corporate, flow-through, employment, and excise and estate and gift tax returns. She also has oversight for two Servicewide offices that focus on IRS civil efforts in detecting and deterring tax fraud, and analyzing and identifying abusive tax transactions, tax schemes, and emerging abusive schemes.

• Recognition & Leadership

Her leadership is reflected in her progressive executive roles within the IRS, including her current position as SB/SE Commissioner, where she oversees a $2.34 billion budget and a staff of over 20,000 employees, and earlier as Deputy Chief of the IRS Independent Office of Appeals, where she worked closely with the Chief of Appeals in leading nationwide programs designed to enable Appeals employees to resolve tax controversies without litigation on a fair and impartial basis.

• Experience

Lia’s career has been built within the Internal Revenue Service across a progression of executive and leadership roles. She currently serves as SB/SE Commissioner. Previously, she served as Deputy Chief of the IRS Independent Office of Appeals, leading nationwide programs to resolve tax controversies without litigation. Prior to that, she served in dual roles as the IRS Chief of Staff and the Taxpayer First Act (TFA) office executive lead; as Chief of Staff, she worked closely with the IRS Commissioner and senior leadership team to implement strategic priorities and initiatives critical to tax administration, and as TFA office executive lead, she oversaw Servicewide implementation of TFA provisions and delivery of the TFA Report to Congress, bringing together a comprehensive taxpayer experience strategy, a holistic training strategy, and a modernized IRS organizational structure. She also previously held positions within the IRS Human Capital Office, including senior advisor to the HCO; Deputy Director, Employment, Talent and Security; and Director, Workforce Relations. She started her leadership journey in the Office of Appeals as a team manager, Collection Area Director, and Appeals Training Director.

 

Edward R. Killen, Esq., Commissioner, Tax Exempt and Government Entities | Internal Revenue Service

Edward Killen is the Commissioner of the Tax Exempt & Government Entities (TE/GE) business operating division of the Internal Revenue Service, where he is responsible for administering the tax laws governing employee retirement plans, tax-exempt organizations, tax-exempt bonds, Indian tribal governments, and federal, state, and local governments. He was selected as TE/GE Commissioner following the retirement of Commissioner Sunita Lough, having served in the role since September 30, 2022. Prior to assuming the TE/GE Deputy Commissioner role in October 2019, he served as the IRS Chief Privacy Officer, leading Privacy, Governmental Liaison and Disclosure (PGLD), where he managed a multi-faceted privacy program and ensured compliance with the Privacy Act, the Freedom of Information Act, the Federal Records Act, and Internal Revenue Code 6103. In 2025, he was promoted to the IRS’s acting chief taxpayer compliance officer, a role in which he enforces tax administration policy while overseeing taxpayer service, compliance efforts, and criminal investigations.

• Education & Credentials

Edward earned a Master’s Certificate in project management from the George Washington University School of Business. He holds a Certified Information Privacy Professional, Government (CIPP/G) credential, a Bachelor of Arts degree in political science from Valdosta State University, and a Juris Doctor degree from the University of Florida Levin College of Law. He is a member of the Florida Bar Association and the United States Tax Court.

• Recognition & Leadership

Edward was appointed a member of the Internal Revenue Service Legal Division Performance Review Board, serving in that capacity in his role as Deputy Division Commissioner, Tax Exempt and Government Entities. His leadership is further reflected in his progressive executive roles within the IRS, including TE/GE Commissioner, IRS Chief Privacy Officer, and Director of Governmental Liaison, Disclosure and Safeguards within PGLD. He began his federal service career as a Presidential Management Fellow.

• Professional Involvement

Edward is a member of the Florida Bar Association and the United States Tax Court, and he served as a member of the IRS Legal Division Performance Review Board.

• Experience

Edward’s career has been built largely within the Internal Revenue Service across a range of executive and leadership positions. He has served as Commissioner of TE/GE since September 30, 2022, succeeding Sunita Lough, and in 2025 was promoted to acting chief taxpayer compliance officer, overseeing taxpayer service, compliance efforts, and criminal investigations. He assumed the TE/GE Deputy Commissioner role in October 2019. Before that, he served as IRS Chief Privacy Officer leading PGLD, where he represented the IRS’s interests across privacy compliance, records management, information protection, disclosure, data sharing, and combating identity theft. He previously served as Director, Governmental Liaison, Disclosure and Safeguards within PGLD, providing oversight of policies and procedures regarding access to and disclosures of Federal Tax Information (FTI) under IRC Section 6103 — encompassing IRS compliance with FOIA, data exchanges with federal, state, and local government agencies, and safeguarding FTI in the custody of exchange partners. He also served as Director of the Office of Safeguards within PGLD and as Senior Advisor to the IRS Deputy Commissioner of Operations Support, providing authoritative counsel and advice. Earlier, he was on a long-term assignment to the IRS Services and Enforcement Affordable Care Act Program Office, where he played a key role in the initial scoping of the IRS’s responsibilities under the act, and before that served as Chief of the Enterprise Continuous Monitoring Branch of the W&I Security Program Management Office. He began his federal service career as a Presidential Management Fellow, with an initial appointment to the Social Security Administration Office of Hearings and Appeals. In 2003, he transferred his appointment and joined the IRS as a policy analyst within W&I Strategy and Finance, where he led the development of the W&I business plan and was part of a small group that stood up the initial Identity Theft program office within the IRS. His numerous detail assignments across the IRS include work within IRS Counsel’s office, the 2008 Economic Stimulus Program, and the Internet Strategy team.

 

Jennifer Breen, Esq., Partner | Morgan Lewis & Bockius

Jennifer Breen is a Partner at Morgan Lewis who represents domestic and multinational businesses, large partnerships, high-net-worth individuals, and family offices on tax controversy and Internal Revenue Service (IRS) administrative matters. She also counsels professional services firms, investment fund managers, and private equity firms on partnership tax issues. With decades of experience spanning government service, a “Big Four” public accounting firm, and in-house as the director of tax controversy for a large multinational corporation, Jennifer offers a rare perspective and an invaluable ability to see tax issues from multiple vantage points. Her proven skills and extensive background include all aspects of tax controversy and litigation, including managing IRS audits, filing and presenting protests in IRS Appeals, and ultimately litigating cases before the United States Tax Court and other federal courts. Drawing on her experience as an attorney with the IRS Office of Chief Counsel’s National Office, she marries substantive tax knowledge with strong relationships at the IRS and firsthand insights into navigating issues, seeking guidance, and understanding administrative processes and federal rulemaking, often seeking to resolve issues at the earliest stage possible through procedural techniques including pre-filing agreements, private letter ruling requests, requests for technical advice, and other informal methods.

• Education & Credentials

Jennifer earned her J.D. from the University of Houston Law Center in 2001 and a B.A. in Political Science and Government from the University of Texas at Austin in 1998. She is admitted to practice in the District of Columbia and Texas, and before the U.S. Court of Appeals for the First Circuit, the U.S. Court of Appeals for the Federal Circuit, the U.S. Court of Federal Claims, and the U.S. Tax Court.

• Recognition & Leadership

Jennifer is listed in Lawdragon’s 500 Leading Global Tax Lawyers for Washington, D.C., Tax, Controversy, Litigation (2025). She is recognized as Highly Regarded for Tax Controversy in the District of Columbia and as a Women in Tax Leader for Tax Controversy in the District of Columbia in International Tax Review’s World Tax Guide (2025, 2026). She is ranked for Tax: Private Client (Nationwide) in the Chambers High Net Worth Guide (2024, 2025) and for Tax in the District of Columbia in Chambers USA (2022–2025), having previously been recognized as Up-and-Coming for Tax in the District of Columbia (2020, 2021). She is recommended for Tax: US taxes: contentious in The Legal 500 US (2019, 2020) and was recommended more broadly in The Legal 500 US (2016). She is listed in The Best Lawyers in America for Tax Law in Washington, D.C. (2022–2026) and recognized by Washingtonian Magazine for Tax (2020). She was named among the Emerging Women Leaders in Private Practice by DCA Live (2019) and was a member of Law360’s Practice Group of the Year for Tax (2017). She received the IRS Special Act Award (2002–2005).

• Professional Involvement

Jennifer is a Fellow of the American College of Tax Counsel and a member of the J. Edgar Murdock Inn of Court. Within the American Bar Association’s Section of Taxation, she serves as a Council Director and previously served as Chair of Administrative Practice (2017–2018). She is a Director and Treasurer of the Washington DC Center for Public Interest Tax Law, a nonprofit tax clinic providing pro bono legal services to taxpayers across the United States, where she oversees clinic operations including regular attendance at United States Tax Court calendar calls and the delivery of pro bono legal representation to low-income taxpayers.

• Experience

Jennifer’s career spans government, public accounting, in-house, and private practice. She served as an attorney with the IRS Office of Chief Counsel’s National Office. Prior to joining Morgan Lewis, she distinguished herself as a trusted in-house advisor for Mattel, an American multinational toy manufacturing and entertainment company, where she gained a keen understanding of all aspects of tax compliance and controversy from an in-house perspective. In that capacity, she was responsible for all matters involving US federal income tax and foreign tax controversies, as well as those involving state and local corporate and business tax, sales and use tax, and escheat and unclaimed property audits, and she managed the company’s global reportable transaction compliance and compliance under the Foreign Account Tax Compliance Act. While with PwC, she represented major corporations, partnerships, S corporations, and individuals in resolving domestic and international controversy issues, counseled clients on risk management matters, and routinely advised on filing and compliance issues as well as other issues arising with accounting, audit, and internal controls. She also routinely advises clients on filing and compliance matters, voluntary disclosures, interest issues, penalty abatement actions, IRS requests and summonses, enforcement proceedings, and joint defense agreements.

 

Diana L. Erbsen, Esq., Partner | DLA Piper

Diana L. Erbsen is a Partner at DLA Piper, based in New York, with more than two decades of experience in tax controversy, representing clients in all aspects of sophisticated, challenging, and often high-stakes tax disputes. In 2014, she was appointed to the position of Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice (DOJ) by President Obama, and following the end of the administration on January 20, 2017, she returned to DLA Piper as a partner. Since returning, she has resumed representing public and privately held corporations, as well as partnerships, estates, and individuals, in all aspects of tax disputes, concentrating her practice on federal, state, and local tax controversies, including criminal tax matters. Informed by her experience at the DOJ and her historical perspective, she regularly counsels clients on issues relating to judicial deference to IRS guidance, including regulations, as well as on the appeal process and the intersection of criminal and civil tax enforcement.

• Education & Credentials

Diana earned an LL.M. from New York University, a J.D. from Northeastern University, and a B.A., cum laude, from Amherst College, where she held the Charles Hamilton Houston Fellowship for Scholarship & Citizenship and the John Woodruff Simpson Fellowship for the Study of Law. She is admitted to the bar in Connecticut, the District of Columbia, and New York. Her court admissions include the Supreme Court of the United States, the United States Tax Court, the United States Court of Appeals for the Federal Circuit, the United States Court of Appeals for the Second Circuit, the United States Court of Federal Claims, the United States District Court for the Southern District of New York, and the United States District Court for the Eastern District of New York. In April 2024, she was awarded a Certification of Successful Completion of Mediation Skills Training by Quinnipiac University Law School’s Center on Dispute Resolution.

• Recognition & Leadership

Diana is ranked by Chambers USA in Band 3 for Nationwide Tax: Controversy (2021–2025), having previously been ranked Band 4 (2020), and was ranked Band 1 for Nationwide Tax: Private Client, High Net Worth (2024). She is recognized by The Legal 500 United States as a Leading Partner for US Taxes: Contentious (2024–2025) and was Recommended in that category (2018–2023). In January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award for her leadership and oversight of the Appellate Section of the Tax Division. She was appointed to the ABA Tax Section’s Appointments to the Tax Court Committee for a five-year term (2024–2029), serves on the American College of Tax Counsel Board of Regents as 2nd Circuit Regent, and was a member of the Law360 Tax Authority Federal 2024 Editorial Board.

• Professional Involvement

In 2020, Diana served as Chair of the IRS Advisory Council (IRSAC), which advises the IRS Commissioner on tax administration issues. Her IRSAC service, along with her roles in the leadership of the American Bar Association Tax Section and the American College of Tax Counsel (for which she currently serves as the 2nd Circuit Regent), facilitates her ability to provide up-to-the-minute guidance to clients and to help improve tax administration for the benefit of taxpayers and the IRS. She has been a member of the J. Edgar Murdock Inn of Court since 2015. She is an active speaker and panelist, having presented at venues including the NYU School of Professional Studies Tax Controversy Forum, the ABA Annual National Institute on Criminal Tax Fraud & Tax Controversy, the DC Bar Tax Conference, and the International Tax Review’s Annual Women in Tax Forum, and is frequently quoted in publications such as Tax Notes, Law360, Forbes, and The Wall Street Journal.

• Experience

Diana served as Deputy Assistant Attorney General for Appellate and Review in the Tax Division of the US Department of Justice. In her capacity as a Presidential appointee to the DOJ’s Tax Division, she oversaw its largest section, the Appellate Section (responsible for all appellate litigation, including to the Supreme Court), the Office of Review (responsible for civil settlements), and the Financial Litigation Unit (tasked with collecting judgments secured by the Trial Sections of the Tax Division). She was actively involved in the management and operations of the Civil and Criminal sections of the Tax Division and served in an ex officio capacity on the Bankruptcy Rules Advisory Committee. Earlier in her career, she served as Attorney-Adviser to the Hon. Robert Armen, Jr. of the US Tax Court. Among the specific, highly skilled areas in which she has had substantial experience are representing clients in connection with subpoenas issued by the Senate Permanent Subcommittee on Investigations; representing clients in art-related matters (including estate and gift tax, auction house guarantees, sales tax, and alleged fraudulent transfers); representing accounting firms and accountants in matters involving their ethical obligations (including pursuant to Circular 230) and their obligations under federal and state tax laws (including relating to material advisor rules, preparer penalties, and disclosure of taxpayer information); and assisting individual and institutional clients in becoming compliant with US tax laws (including with regard to undisclosed foreign financial accounts and assets).

 

Hon. Patrick J. Urda, Chief Judge | United States Tax Court

Patrick J. Urda is the Chief Judge of the United States Tax Court. Born in Indiana, he was appointed by President Trump as Judge of the United States Tax Court and sworn in on September 27, 2018, for a term ending September 26, 2033. He was elected Chief Judge for a two-year term effective June 1, 2025.

• Education & Credentials

Judge Urda received a Bachelor of Arts degree, summa cum laude, from the University of Notre Dame and a Juris Doctor from Harvard Law School.

• Recognition & Leadership

His Bachelor of Arts was conferred summa cum laude from the University of Notre Dame. His leadership is reflected in his election as Chief Judge of the United States Tax Court, effective June 1, 2025, for a two-year term.

• Professional Involvement

Judge Urda formerly served as an Adjunct Professor of Law at American University Washington College of Law.

• Experience

Prior to his appointment to the Court, Judge Urda practiced law with McDermott Will & Emery and with Maciorowski, Sackmann & Ulrich. He served as a Law Clerk to Judge Daniel A. Manion of the U.S. Court of Appeals for the Seventh Circuit and held several positions with the U.S. Department of Justice’s Tax Division, including details as Counsel to the Deputy Assistant Attorney General for Appellate and Review and to the Criminal Division’s Office of Overseas Prosecutorial Development Assistance and Training. He was appointed to the United States Tax Court and sworn in on September 27, 2018, for a term ending September 26, 2033, and was elected Chief Judge effective June 1, 2025.

 

Kenneth J. Kies, Esq., Acting Chief Counsel, Internal Revenue Service; Assistant Secretary, Tax Policy | US Department of the Treasury

Kenneth J. Kies serves as Assistant Secretary of the U.S. Department of the Treasury for Tax Policy, the senior advisor to the Secretary of the Treasury responsible for analyzing, developing, and implementing federal tax policies and programs. Nominated by President Trump in January 2025, he was confirmed by the United States Senate on June 26, 2025, by a vote of 53-45, and reports directly to Treasury Secretary Scott Bessent. He has devoted his professional career to federal tax policy and law in both the public and private sectors, having worked on virtually every aspect of the tax code. He stepped down as Managing Director of the Federal Policy Group, LLC on March 14, 2025, a position he had held since February 2002.

• Education & Credentials

Kenneth Kies attended college at Ohio University in Athens, Ohio. He began the practice of law in 1977 in Cleveland after graduating from the Ohio State University College of Law.

• Recognition & Leadership

Kenneth Kies’s leadership is reflected in his senior governmental and professional roles, including Assistant Secretary of the Treasury for Tax Policy, Chief of Staff of the Joint Committee on Taxation, and Chief Republican Tax Counsel to the House Committee on Ways and Means. In 1997, he initiated a year-long project to analyze the potential for macroeconomic estimates of major tax policy changes, resulting in the publication of the Joint Committee on Taxation Tax Modeling Project in December 1997 — at the time the most significant project of its kind and the beginning of an estimating capability that continues at the Joint Committee to this day. He served as Co-Chair, with Michael Boskin (former Chair of the Council of Economic Advisers for President George H.W. Bush), of the 1996 Ways and Means Retreat on Tax Reform under Chairman Bill Archer.

• Professional Involvement

After leaving the Joint Committee in January 1998, Kenneth Kies continued to serve at the request of Speaker Newt Gingrich and Chairman Archer in an effort to negotiate a permanent long-term solution to the solvency of the Social Security system with the Clinton Administration, in particular with Gene Sperling and Larry Summers. That effort culminated in his participation in the December 1998 White House Conference on Social Security, alongside fellow panelists Martin Feldstein (former Chair of the Council of Economic Advisers under President Ronald Reagan) and Robert Reischauer (former head of CBO); the project is recounted in a book on the history of the Social Security system entitled The People’s Pension.

• Experience

Kenneth Kies’s career spans congressional staff service, private legal practice, public accounting, and tax-policy consulting. He began the practice of law in 1977 as a tax associate with BakerHostetler in Cleveland. From 1981 until 1987, he served as Chief Republican Tax Counsel to the House Committee on Ways and Means, where he was actively involved in the development of all tax legislation, including the Economic Recovery Tax Act of 1981 and the Tax Reform Act of 1986. He subsequently served as the firmwide Chair of the Tax Practice for BakerHostetler. He served as Chief of Staff of the Joint Committee on Taxation from 1995 until 1998, overseeing development of major tax legislation including the Taxpayer Relief Act of 1997 (the first net tax cut since the 1981 Act), the Small Business Job Protection Act of 1996, and the Health Insurance Portability and Accountability Act of 1996, and helping design and negotiate the IRS Restructuring Act of 1998 with Congressman Rob Portman, Senator Ben Cardin, and Secretary of the Treasury Robert Rubin. He then served as Co-Managing Partner of the Washington National Tax Services office of PricewaterhouseCoopers LLP. From February 2002 until March 14, 2025, he was Managing Director of the Federal Policy Group, LLC, a private-sector firm providing advocacy, strategic consulting, and technical advice on tax policy matters before Congress, the Treasury Department, and the Internal Revenue Service. He was confirmed as Assistant Secretary of the Treasury for Tax Policy in June 2025.

 

Christopher M. Ferguson, Esq., Partner | Kostelanetz

Christopher M. Ferguson is a Partner at Kostelanetz LLP, based in New York City, with over two decades of experience as a litigator. He concentrates his practice on white-collar criminal defense as well as civil and criminal tax controversies and other regulatory enforcement matters and also has extensive experience handling complex civil litigation and internal investigations. Chris represents clients in both federal and state courts, as well as before governmental agencies and other regulatory bodies, including the U.S. Department of Justice, the Internal Revenue Service, the Securities and Exchange Commission, FINRA, the New York Attorney General’s Office, the U.S. Department of Labor, the New York City Department of Investigations, and the Manhattan District Attorney’s Office. He has defended clients in federal and state investigations and prosecutions involving allegations of tax fraud, securities fraud, criminal anti-trust violations (bid rigging and price fixing, including in the foreign exchange market), Bank Secrecy Act violations, mail and wire fraud, CARES Act fraud, prevailing wage fraud, theft of government services, fraud related to state and local Minority and Women Business Enterprise (MWBE) programs, and other violations of federal and state law. He also conducts internal investigations for institutional clients whose officers or employees have been suspected or accused of wrongdoing.

• Education & Credentials

Chris received his B.A., magna cum laude, from Boston College in 1994, and his J.D. from New York University School of Law in 1999. He is admitted to practice in New York State (2000), the U.S. District Court for the Southern District of New York (2001), and the U.S. District Court for the Eastern District of New York (2001).

• Recognition & Leadership

Chris is recognized in Super Lawyers for Criminal Defense: White-Collar in New York, and in Best Lawyers for Commercial Litigation and for Litigation and Controversy – Tax in New York. The Legal 500 describes him as a “key lawyer” at the Firm, and International Tax Review/World Tax describes him as “highly regarded” in the area of tax controversy. He is the former Secretary of the Criminal Law Committee of the New York City Bar Association.

• Professional Involvement

Chris is a member of the New York Council of Defense Lawyers and is the former Secretary of the Criminal Law Committee of the New York City Bar Association, having been a member of that committee since 2010. He publishes and speaks extensively in the areas of white-collar crime and civil and criminal tax controversies, with recent speaking engagements including “Tax Enforcement Trends: What’s Hot and What’s Not” (November 2024) and “Employee Retention Credit Update: Current Knowledge and Future Projections” (July 2024), and recent publications including “Defending a Pandemic Fraud Prosecution” (September 2025) and “Demystifying DeFi: Tax Compliance for Individuals Engaging In Decentralized Finance (DeFi) Transactions” (July 2025).

• Experience

In his civil practice, Chris has represented both plaintiffs and defendants in a variety of complex commercial and regulatory matters, including wage and hour class actions, Department of Labor investigations, tax shelter litigations, government procurement matters, and commercial litigations involving breach of contract, breach of fiduciary duty, fraudulent conveyances, civil fraud, civil RICO, civil forfeiture, and similar claims. Prior to joining Kostelanetz LLP, he served as a law clerk to the Honorable Jay C. Waldman of the United States District Court for the Eastern District of Pennsylvania, and was associated with the law firm of Dewey Ballantine, LLP, where he practiced in the areas of complex commercial, antitrust, and bankruptcy litigation. Among his representative matters, he has persuaded prosecutors not to charge clients and obtained non-prosecution agreements in numerous criminal tax and white-collar investigations, successfully persuaded the Office of IRS Appeals to fully abate fraud penalties assessed against a hedge fund manager, represented multiple taxpayers in tax shelter litigations in federal district courts and tax court, and conducted internal investigations for not-for-profit, quasi-governmental, and public-company clients involving suspected embezzlement, bribery, wage violations, and regulatory misconduct.

 

Megan E. Marlin, Esq., Principal | PwC

Megan E. Marlin is a Principal at PricewaterhouseCoopers LLP (PwC) in Washington, DC, specializing in compensation and benefits, with a practice focused on employment tax consulting and compliance within the firm’s Workforce Transformation group. She advises for-profit and tax-exempt employers on worker classification, fringe benefits, global mobility, remote and hybrid work arrangements, compensation arrangements, legal entity simplification, payroll transformation, post-deal integration, and federal and state payroll tax compliance. She also represents clients before the IRS and state taxing authorities to negotiate settlement agreements, manage penalty abatement requests, and lead audit and appeals defense. Prior to rejoining PwC, Megan served as Legislation Counsel for the nonpartisan Joint Committee on Taxation, where she advised Members of Congress, the House Committee on Ways and Means, and the Senate Finance Committee in the areas of employment tax, executive compensation, retirement plans, and healthcare.

• Education & Credentials

Megan graduated from the College of William & Mary in 2006 with a B.A. in International Relations. She subsequently received a J.D., cum laude, from Suffolk University Law School and an LL.M. in Taxation, specializing in Employee Benefits, from Georgetown University Law Center.

• Recognition & Leadership

Megan is the US Domestic leader for the Global Employment Tax network at PwC and is the former chair of the Employment Taxes committee of the American Bar Association. At William & Mary, she was a captain of the Division I volleyball team, a representative on the Student Athletic Advisory Council, and co-founder of the William & Mary chapter of the pre-law fraternity Phi Alpha Delta.

• Professional Involvement

Megan serves as a member of the William & Mary Washington Center Advisory Board. She is a frequent panelist for the American Bar Association, the Maryland State Bar Association, the Tax Executive Institute, and the Practicing Law Institute, and is the former chair of the ABA’s Employment Taxes committee.

• Experience

Megan is a Principal at PwC, where she advises employers on corporate restructuring and payroll transformation, global mobility, fringe benefits, equity compensation, worker classification, tax controversy, and the federal and state payroll tax compliance function. She has significant experience counseling employers on travel expense reimbursements, fringe benefits, worker classification, equity compensation, third-party payroll arrangements, U.S. employment taxes for inbound and outbound employees, and the employment tax consequences of change-of-control events, and she represents taxpayers before the IRS to negotiate settlement agreements and navigate IRS examinations and appeals. Prior to rejoining PwC, she served as Legislation Counsel with the Joint Committee on Taxation, where she assisted congressional tax-writing committees and Members of Congress with the development and analysis of legislative proposals. Earlier in her career, before joining PwC, she was an attorney specializing in tax controversy and employment taxes at a mid-sized law firm in Baltimore, Maryland, where she assisted companies with the negotiation of installment agreements and offers in compromise with the IRS and advised clients on general tax matters.

 

Daniel Graham Strickland, Esq., Partner | Holland & Knight

Daniel Graham Strickland is a Partner and tax attorney in Holland & Knight’s Washington, D.C., office. He focuses his practice in the area of federal tax controversy, representing taxpayers in all types of tax controversy matters, and also focuses on the renewable energy sector, advising clients on energy tax credits and incentives from conception to litigation. In the context of tax controversy, he guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases throughout the United States, with experience covering a wide range of procedural and complex tax issues, including valuation, foreign and energy tax credits, classification of investment as debt or equity, judicial substance doctrines, and penalty defenses. In the energy sector, he advises clients on tax credits, such as investment tax credits (ITCs), production tax credits (PTCs), carbon capture, hydrogen, electric vehicle, fuels, and other energy tax credits, including through the Inflation Reduction Act (IRA) and on the impact of fuels, oil spill, and Superfund excise taxes to current and anticipated business operations.

• Education & Credentials

Daniel earned his LL.M., with distinction, from Georgetown University Law Center; his J.D., magna cum laude, from the Charleston School of Law; and his B.S. from the University of South Carolina. He is admitted to the bar in the District of Columbia. His court admissions include the U.S. Supreme Court, the U.S. Tax Court, the U.S. District Court for the District of Columbia, and the U.S. Courts of Appeals for the Second, Fourth, Fifth, Ninth, and Eleventh Circuits. While in law school, he served as the research editor for the Charleston Law Review.

• Recognition & Leadership

Daniel was named a John S. Nolan Fellow by the American Bar Association (ABA) Section of Taxation for 2024-2025. He is recognized in The Best Lawyers in America guide as “Ones to Watch” for Washington, D.C. Litigation and Controversy, Tax (2021-2025) and for Washington, D.C. Energy Law and Tax Law (2024, 2025). His leadership roles include serving as Section Chair of the Federal Bar Association’s Section on Taxation (2022-2023) and as Vice Chair of the ABA Section of Taxation’s Energy & Environmental Taxes Committee (2022-Present).

• Professional Involvement

Daniel is active in several professional organizations. Within the Federal Bar Association (FBA) Section on Taxation, he served as Section Chair (2022-2023), is Past Co-Chair of the Tax Practice and Procedure Committee and has been a Steering Committee Member since 2017. Within the American Bar Association (ABA) Section of Taxation, he serves as Vice Chair of the Energy & Environmental Taxes Committee (2022-Present) and previously served as Technology Liaison to the Court Practice and Procedure Committee (2021-2022). He is also a member of the D.C. Bar Association’s Taxation Community and is Past Chair of its New Tax Practitioner Subcommittee. He represents clients in the traditional and renewable energy sectors in legislative and regulatory efforts, including in obtaining public and private guidance from the U.S. Department of the Treasury and the IRS.

• Experience

Prior to joining Holland & Knight, Daniel was an attorney for a global law firm in its Washington, D.C., office. Previously, he served as a law clerk at the U.S. Tax Court for the Honorable Albert G. Lauber, the Honorable Elizabeth Crewson Paris, and the Honorable Michael B. Thornton. He represents clients in tax controversy matters at the administrative, trial court, and appellate levels, guiding them through IRS audits, preparing administrative claims and protests of IRS actions, and litigating tax and tax-related cases throughout the United States. In the energy sector, his work spans advising clients on a broad range of energy tax credits and incentives and on the impact of fuels, oil spill, and Superfund excise taxes, as well as representing clients in legislative and regulatory efforts before the U.S. Department of the Treasury and the IRS.

 

Leila D. Carney, Esq., Member | Caplin & Drysdale, Chartered

Leila D. Carney is a Member at Caplin & Drysdale, based in Washington, D.C., and a seasoned tax lawyer with a focus on resolving disputes with the IRS. Her core practice involves providing a surgical defense to IRS audits, assessments, and penalties, including litigation in the Court of Appeals for the D.C. Circuit, the U.S. Tax Court, Federal District Court, and the D.C. Circuit Court against the IRS and the Department of Justice. She is adept at handling multifaceted issues involving global business and investing structures for individuals, corporate clients, and complex trusts, and has handled sensitive IRS exams, administrative appeals, criminal matters, Circular 230 disciplinary proceedings, represented subpoenaed witnesses, and submitted ruling requests and comment letters on proposed regulations. She has practiced in the Tax Disputes & Tax Litigation Group since first joining Caplin & Drysdale’s Washington, D.C. office in 2004, and also provides her tax, litigation, and federal law expertise to the firm’s Complex Litigation, Criminal Tax & White Collar Defense, Private Client, and Political Law Practices.

• Education & Credentials

Leila earned her J.D. from the University of Virginia School of Law in 2004 and her B.A. from The College of William & Mary in 2001. She is admitted to practice in the District of Columbia and Virginia, and before the U.S. Court of Appeals for the D.C. Circuit, the U.S. Tax Court, the U.S. District Court for the Eastern District of Virginia, and the D.C. Circuit Court.

• Recognition & Leadership

Leila serves on the Tax Notes Federal Advisory Board, shaping content for Tax Analysts, a leading publisher on tax law and policy. She was elected a Member of Caplin & Drysdale in October 2023. Her thought leadership is reflected in her frequent commentary in outlets including Bloomberg Law, Tax Notes, Law360, Financial Planning, Accounting Today, MarketWatch, The Hill, and others, on matters such as Moore v. United States, the Chevron decision, the Corporate Transparency Act, and regulatory authority in tax legislation.

• Professional Involvement

Leila is a Member of the Tax Notes Federal Advisory Board, the American Bar Association’s Section of Taxation, and the District of Columbia Bar. Within the ABA Tax Section, she has led the Administrative Practice Committee on the IRS LB&I Puerto Rico Campaign (August 2024). She is an active speaker and author, with engagements including the NYU Tax Controversy Forum (exploring the Employee Retention Credit, June 2026), and publications appearing in the Pittsburgh Tax Review, Practical Tax Strategies (Thomson Reuters), Procedurally Taxing, and the firm’s Tax and International Tax Alerts on topics such as the Corporate Transparency Act, Puerto Rico residency audits, conservation easements, and refund claims.

• Experience

Throughout her career, Leila has zealously won an appeal to the D.C. Circuit Court of Appeals, converting a Tax Court loss into a win; litigated cases involving foreign-source income, captive insurance, conservation easements, and IRS third-party summonses; defended Puerto Rico residency and sourcing in IRS campaign audits; navigated the Congressional Joint Committee on Taxation large tax refund review process; defended a gift tax return examination involving a high-net-worth trust structure; sought full abatement of civil penalties related to foreign trust reporting, return preparer penalties, and appraiser penalties; sought full allowance of large deductions in IRS “hobby loss,” “cost segregation,” and “real estate professional” examinations, and a refund of Net Investment Income Tax (NIIT); assisted victims of criminal tax return preparers in providing testimony and correcting returns; coordinated reinstatement of an inadvertent S-corp termination; sought “9100” relief for missed “check the box” elections; and advised on presidential ballot access law and procedure. She has represented clients in sensitive audits with a risk of allegations of tax fraud or securities fraud, assisted clients responding to subpoenas for civil and criminal proceedings and those under investigation, and protested civil penalties including those specific to foreign bank accounts, trusts, gifts, preparers, promoters, and appraisers. She has represented clients on voluntary disclosures and collection matters such as offers-in-compromise, lien releases, installment agreements, decertifying passports, and innocent spouse petitions; assisted with state tax aspects such as California Franchise Tax Board exams, resolution programs, and collection activities; and is experienced in obtaining and defending tax-exempt status for public and private charities as well as trade associations. She has also advised clients on creating business practices that comply with changing regulatory regimes, including those governing taxpayer consent to disclosure of tax return information, foreign bank account reporting (FBAR), and nonqualified deferred compensation plans, and has assisted clients in submitting comments on proposed regulations.

 

Eric Hylton, National Director | alliant

Eric Hylton is a National Director (National Director of Compliance) at alliantgroup and the former IRS Commissioner of the Small Business/Self-Employed (SB/SE) Division, a position to which he was appointed in September 2019. He spent approximately 30 years at the Internal Revenue Service, where he held several prominent positions, including serving as Deputy Chief of the Criminal Investigation (CI) Division and as CI’s head of International Operations. As National Director at alliantgroup, he employs his years of experience at the IRS to assist the firm’s clients, serving as an ambassador for U.S. small and medium-sized businesses (SMBs) and helping others become tax compliant.

• Education & Credentials

Eric attended Morehouse College.

• Recognition & Leadership

Eric is the former chair of the Organization for Economic Cooperation and Development (OECD) Task Force for Tax Crimes and Other Financial Crimes. As Chair, he led a multilateral commission of 40 international criminal tax organizations to develop methodologies and typologies on emerging global criminal tax and financial crimes threats — work that resulted in significant legislative changes, billions in revenue, and the establishment of joint international investigative teams. His leadership is further reflected in his senior IRS roles, including Commissioner of the SB/SE Division, Deputy Chief of the Criminal Investigation Division, and head of CI’s International Operations.

• Professional Involvement

In his role at alliantgroup, Eric serves as an ambassador for U.S. small and medium-sized businesses and assists clients in becoming tax compliant. He also served as the former chair of the OECD Task Force for Tax Crimes and Other Financial Crimes, and has served as Director of Investigations for Zerbe, Miller, Fingeret, Frank & Jadav LP (ZMF Law), advising clients on criminal tax investigations, tax controversy matters, internal investigations, cryptocurrency, and whistleblower claims.

• Experience

Eric’s career has spanned approximately 30 years of senior leadership at the IRS, subsequent private-sector roles, and his current position at alliantgroup. Within the IRS, he held positions including Commissioner of the Small Business/Self-Employed Division (appointed September 2019), Deputy Chief of the Criminal Investigation Division, Executive Director / head of CI’s International Operations, and Director of CI’s Narcotics and Counterterrorism Office. Among his select career accomplishments, in civil investigation he directed the IRS’s Audit and Collection tax operations with a $2.2 billion yearly budget and 20,000 nationwide employees, with oversight for 800,000 audits and billions of tax dollars assessed and collected. In criminal investigation, he oversaw the sixth-largest U.S. federal law enforcement agency, with a worldwide staff of approximately 3,000 employees that resulted in over 6,000 investigations recommended for prosecution, leading to thousands of individuals convicted and sentenced. In fraud investigation, he revolutionized the IRS’s National Fraud Program — establishing emerging threat teams, revamping organizational structure, revising metrics, and streamlining processes that resulted in multimillion-dollar fraud schemes being referred for criminal purposes. In the area of international partnership, he led a multilateral commission of 40 international criminal tax organizations to establish global methodologies on emerging financial fraud threats, resulting in significant legislative changes, billions in revenue, and the establishment of joint international investigative teams. He later served as Director of Investigations for ZMF Law before his role as National Director at alliantgroup.

 

Elizabeth J. Stevens, Esq., Member | Caplin & Drysdale, Chartered

Elizabeth J. Stevens is a Member of Caplin & Drysdale, based in Washington, D.C., who practices across the firm’s International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups. Her client representations span international tax and transfer pricing planning and advocacy for multinational corporations; U.S. investment and business structuring and transactional advice for foreign corporate groups; and domestic and cross-border tax structuring, transactional, and compliance advice to high-net-worth individuals and their privately held businesses. In the transfer pricing space, she advises corporate clients on planning, documentation, and compliance, with a particular focus on dispute resolution and prevention and tax certainty processes such as the Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APAs), and she regularly advises on other treaty-related matters such as the creation and taxation of permanent establishments, relief from double taxation for U.S. citizens resident outside the United States, corporate and individual tax residency determinations, and eligibility for treaty benefits.

• Education & Credentials

Elizabeth earned her LL.M. in Taxation from New York University School of Law in 2014, where she received the Harry J. Rudick Memorial Award; her J.D., summa cum laude, from California Western School of Law in 2008; and her B.S. in Foreign Service, magna cum laude, from Georgetown University in 2002. She is admitted to practice in California and the District of Columbia, and before the U.S. Supreme Court and the U.S. Tax Court.

• Recognition & Leadership

Elizabeth is recognized by The Legal 500 as Recommended (2020-2024). Her leadership in the profession includes serving as a Council Director of the American Bar Association’s Section of Taxation and as former Chair of the ABA Section of Taxation’s Transfer Pricing Committee. She is also a frequent author and speaker, with thought-leadership commentary appearing regularly in outlets such as Law360, Bloomberg Law/Bloomberg Tax, Tax Notes, and the IBFD International Transfer Pricing Journal.

• Professional Involvement

Elizabeth serves as a Council Director of the American Bar Association’s Section of Taxation, is a Member of the U.S. Council for International Business, and serves on Caplin & Drysdale’s Talent Strategy Committee, in addition to her role as former Chair of the ABA Section of Taxation’s Transfer Pricing Committee. She is an exceptionally active speaker on international tax and transfer pricing, presenting and chairing panels at venues including the ABA U.S. and Europe Tax Practice Trends Conference, the OECD/USCIB International Tax Conference, the NYU Tax Controversy Forum, the NABE Transfer Pricing Symposium, PLI’s Basics of International Taxation, the ITR Women in Tax Forum, and TP Minds, among many others. Her extensive published work spans transfer pricing, treaty matters, the OECD Pillars, global worker mobility, GILTI and BEAT, partnership audit rules, and Puerto Rico residency audits.

• Experience

Elizabeth began her professional life as a U.S. naval officer. After earning her law degree, she practiced for several years in civil litigation, estate planning, employment matters, and general business advisory and transactions, with roles before joining Caplin & Drysdale that included positions at a private law firm and a nonprofit organization, as well as clerkships with then-Chief Judge Royce Lamberth of the U.S. District Court for the District of Columbia and Judge Robert A. Wherry, Jr. (Ret.) of the U.S. Tax Court. She discovered her calling as a tax lawyer at New York University School of Law, where she earned her LL.M. in Taxation, and continues to leverage her broader lawyering experience as a trusted counselor for clients. Outside the treaty context, her international tax work emphasizes comprehensive planning and advisory services for individuals who are or wish to become bona fide residents of Puerto Rico and the U.S. Virgin Islands, and she provides tax planning, structuring, and transactional representation to individual and corporate clients, with a focus on foreign companies, individuals, and tax-exempt persons investing or conducting business in the United States, including advice to employees and employers on the tax implications of remote and mobile work arrangements. In the cross-border and purely domestic contexts, she assists partnerships, LLCs, and S-corporations with M&A transactions, business restructurings, and the drafting and negotiation of stock and asset purchase agreements, partnership and LLC operating agreements, employment agreements, and other key transaction documents, and advises tax partnerships and S-corporations on federal income tax planning, structuring, and compliance matters.

 

Joseph A. DiRuzzo, III, Esq., CPA, Partner | Margulis Gelfand DiRuzzo & Lambson

Joseph A. DiRuzzo, III is an attorney and Certified Public Accountant with DiRuzzo & Company, based in Fort Lauderdale, Florida. His practice spans tax controversy, health care, digital assets, tax planning, white collar criminal defense, Virgin Islands taxation, appellate practice, and complex civil and governmental litigation. He brings a combined legal and accounting background to his work, having argued numerous appeals before multiple United States Courts of Appeals and tried cases before the U.S. Tax Court, and he is a Florida Bar Board Certified Specialist.

• Education & Credentials

Joseph earned his Juris Doctor from the University of Miami School of Law, an LL.M. in Healthcare Law from Loyola University Chicago School of Law, a Master of Accounting from the University of Connecticut School of Business, a B.S. in Business & International Affairs (dual major) from Mary Washington College, and a B. Accounting from Florida International University. He is licensed as an Attorney in Florida, New York, New Jersey, and the United States Virgin Islands; as a Certified Public Accountant in Florida; and as a Solicitor in England & Wales. He is a Florida Bar Board Certified Specialist (BCS) in Criminal Appellate Law (2013). His court admissions include the U.S. Supreme Court; the 1st, 2nd, 3rd, 4th, 8th, 9th, 11th, Federal, and D.C. Circuits; the U.S. Tax Court; the U.S. Court of Federal Claims; the U.S. Court of International Trade; and numerous U.S. District Courts, including the Southern and Middle Districts of Florida, the District of the Virgin Islands, the District of New Jersey, the Southern District of New York, the Western District of Michigan, the D.C. District, the Northern District of Illinois, and the District of Colorado.

• Recognition & Leadership

Joseph obtained Florida Bar Board Certification as a Specialist in Criminal Appellate Law (2013). Earlier in his career, he was awarded Attorney of the Year 2003 in the County Division at the Office of the Public Defender, where he held the office trial record. His thought leadership in the field is reflected in his speaking engagements, including panels and presentations for the American Bar Association Tax Section and the Florida Institute of Certified Public Accountants.

• Professional Involvement

Joseph has served as a panelist and presenter at numerous professional conferences. His speaking engagements include “Ensuring Ethical Client Solicitations” (ABA Tax Section, 2015 May Meeting); “Accounting for Bitcoin” (Florida Institute of Certified Public Accountants, 30th Annual Accounting Show, September 2015); “Civil and Criminal Enforcement Tools for Use Against Overseas Taxpayers and Taxpayers with Overseas Assets” (ABA Tax Section, 2016 October Meeting); “How to Affirmatively Defend an FBAR Case” (ABA Tax Section, 2017 January Meeting); and “CPAs Civil & Criminal Liability in Tax Practice” (Florida Institute of Certified Public Accountants, 2018 Accounting & Business Show, September 2018).

• Experience

Joseph’s career spans private tax and white collar practice, public accounting, and public defense. At DiRuzzo & Company, he argued six federal appeals and tried Tax Court cases including Meggs v. Comm’r and Rademacher v. Comm’r, served as an expert witness, and acted as class-action counsel against the Government of the Virgin Islands. At Fuerst Ittleman David & Joseph, PL, he argued before seven U.S. Courts of Appeals and the Virgin Islands Supreme Court, represented NYC police unions in the “stop and frisk” litigation (Floyd v. City of New York), won United States v. Hom (an FBAR case of first impression in the Ninth Circuit), and obtained a full trial acquittal in United States v. Williams. At the Law Office of Marjorie Roberts, PC, he was lead counsel on numerous U.S. Tax Court and Virgin Islands tax cases involving alleged tax shelters, residency disputes, and summons enforcement. At PricewaterhouseCoopers, LLP, he drafted tax opinions on multinational restructurings and assisted with SEC filing tax calculations. At the Office of the Public Defender, he handled all stages of litigation, from dispositive motions through jury trials and appeals.

 

Phillip Colasanto, Esq., Senior Associate | Withers Bergman

Phillip Colasanto is a Senior Associate in the private client and tax team at Withers, based in New York. His practice is focused on domestic and international tax controversy and compliance matters. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts, handling matters from audit through trial and at the appellate level. His experience includes examinations, collection matters, Appeals hearings (including collection due process hearings), innocent spouse relief, whistleblower claims, advising clients on international and domestic filing requirements and compliance options, and oral argument before the Tax Court and Court of Appeals.

• Education & Credentials

Phillip earned an LL.M. and a JD from New York Law School, and a BA from Wagner College. He is admitted to practice in New York (2011) and New Jersey (2010), as well as before the United States Tax Court; the U.S. District Courts for the District of New Jersey, the Eastern District of New York, and the Southern District of New York; and the U.S. Courts of Appeals for the Second and Third Circuits.

• Recognition & Leadership

Phillip received the New York County Lawyers’ Association Pro Bono Award in 2022 and was recognized as a John S. Nolan Fellow by the American Bar Association in 2019-2020. He is heavily involved with the American Bar Association, where he serves as Chair of the Tax Collections, Bankruptcy and Workouts Committee.

• Professional Involvement

Phillip is a member of the American Bar Association, where he chairs the Tax Collections, Bankruptcy and Workouts Committee. He speaks frequently on tax topics at forums including the American Bar Association, the New York County Lawyers’ Association, the IRS Nationwide Virtual Tax Forum, CPA Academy, and the NYU Tax Controversy Forum. He has published numerous tax-related articles in outlets such as Tax Notes, Bloomberg BNA, the Journal of Tax Practice and Procedure, the EA Journal, and The Practical Lawyer, on subjects including international information reporting, supervisory approval of penalties under IRC Section 6751(b), collection due process deadlines, and IRS summons practice.

• Experience

Phillip joined Withers in 2023 and practices in the private client and tax team. His tax controversy and compliance work spans examinations, collection matters, Appeals and collection due process hearings, innocent spouse relief, and whistleblower claims, and he has represented clients from audit through trial and on appeal, including oral argument before the U.S. Tax Court and the U.S. Court of Appeals. He advises clients on domestic and international filing requirements and compliance options, and his published and speaking work reflects deep engagement with tax controversy topics such as voluntary disclosures, conservation easements, civil tax fraud litigation, the Corporate Transparency Act, foreign financial reporting and enforcement, and the substantiation of tax positions.

 

Daniel N. Price, Esq., Managing Member | Law Offices of Daniel N. Price

Daniel “Dan” N. Price is the managing member of the Law Offices of Daniel N. Price, PLLC, based in San Antonio, Texas. His legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities, including civil defense of IRS audits and criminal defense of IRS criminal investigations. For over nineteen years, he served as an attorney for the Office of Chief Counsel of the Internal Revenue Service, and as a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, he brings unique experience with tax controversy and tax administration. He has deep expertise concerning the IRS’s Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, and international penalty regimes, and he assists taxpayers in coming into compliance and in battling significant IRS and state tax penalties.

• Education & Credentials

Dan earned his J.D. with Honors from the University of Texas School of Law (May 2002), where he passed the Uniform CPA Exam and served on the editorial boards of two law journals. He earned a Master of Science in Accounting from Trinity University (May 1999, cumulative GPA 4.00/4.00) and a B.B.A. in Accounting from The University of Texas at San Antonio (May 1998, cumulative GPA 4.00/4.00), where he was recognized as the College of Business’s graduating senior with the highest GPA. He is licensed to practice law in Texas and New York, and for federal tax and federal immigration matters he accepts clients nationally.

• Recognition & Leadership

In February 2025, the American College of Tax Counsel elected Dan as a Fellow, recognizing his experience practicing tax law. During his tenure with the IRS Office of Chief Counsel, he received numerous awards, including the LB&I Public Service Recognition Award (May 2016) for his contribution to the Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures Team; the Deputy Commissioner for Services and Enforcement Award (December 2015); the Chief Counsel Superior Achievement Award for Legal Support (December 2014); the SBSE Division Counsel Client Service Award (April 2012) for outstanding IRS training efforts; and the 2009 SBSE Division Counsel Attorney of the Year.

• Professional Involvement

Dan is a frequent guest speaker at legal events across North America, having given presentations in the United States, Mexico, and Canada on international compliance issues. He volunteers as a member of the American Bar Association, contributing to various ABA comment projects, and as a member of the Form 3520 Task Force of the American Institute of Certified Public Accountants (AICPA). He maintains an active pro bono practice — spending 2022 as volunteer in-house counsel with a nonprofit, representing low-income taxpayers pro bono in Tax Court and administrative proceedings, and handling immigration asylum matters. He occasionally writes tax-related articles and blog posts, including for Tax Notes and Procedurally Taxing, authored “A Plain Language Handbook on the IRS Voluntary Disclosure Practice,” and provides input to the Department of Treasury and the IRS on proposed regulations, such as those relating to foreign trust and foreign gift reporting and Forms 3520 and 3520-A.

• Experience

For over nineteen years, Dan served as an attorney for the IRS Office of Chief Counsel, departing the government at the end of 2021. His government service included extensive work in international enforcement, including assisting the IRS in completely revising the Voluntary Disclosure Practice (including the new instructions for Form 14457), and work with the Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting (FBAR), Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, and international collection of taxes. He served as a Chief Counsel “FBAR Coordinator,” reviewing willful FBAR penalty cases proposed by IRS revenue agents, and was part of the Chief Counsel team that met quarterly with the Department of Justice Tax Division on FBAR cases and annually on significant international enforcement matters. In July 2014, the Chief Counsel appointed him Managing Counsel of the Austin, Texas, post of duty. He provided numerous training sessions to IRS and Chief Counsel personnel across the United States and Puerto Rico, taught as an instructor in Chief Counsel schools such as Discovery School and Advanced Trial Advocacy School, and served as a spokesperson for the IRS. He departed the government at the end of 2021 as a valued member of the teams overseeing the Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, the Relief Procedures for Certain Former Citizens, and other projects with national and international scope. He also litigated tax cases in the United States Tax Court, and in immigration asylum matters has handled defensive asylum claims in Immigration Court removal proceedings and affirmative asylum claims before U.S.C.I.S.

 

Miri Forster, Esq., Partner and National Tax Controversy Leader | EisnerAmper

Miri Forster is a Partner at Eisner Advisory Group LLC and National Leader of the firm’s Tax Controversy & Dispute Resolution practice group, based in Iselin, New Jersey. She specializes in providing tax dispute resolution services to public and private corporations, partnerships, and high-net-worth individuals on a wide range of technical and procedural issues, with over 20 years of IRS practice, procedure, and tax controversy experience. She represents businesses and individuals before the IRS Examination and Appeals Divisions on complex domestic and international tax issues, obtains private letter rulings from the IRS National Office (including 9100 relief requests for missed elections), assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors, obtains penalty abatements and refunds, resolves IRS account issues, and advises on a broad range of IRS practice, procedure, and dispute resolution matters.

• Education & Credentials

Miri earned a BA in Economics from Brandeis University, a JD from New England Law | Boston, and an LLM in Taxation from Georgetown University Law Center.

• Recognition & Leadership

Miri has been recognized by International Tax Review/World Tax as a “Highly Regarded” tax controversy practitioner and a “Women in Tax” leader, named to those rankings for four consecutive years (including the 2023, 2024, and 2026 lists). She was named a 2022 honoree of the Executive Women of New Jersey’s Policy Makers. As National Leader of EisnerAmper’s Tax Controversy & Dispute Resolution practice, she also co-chairs the Women of EisnerAmper, New Jersey Chapter.

• Professional Involvement

Miri is a member of the American Bar Association’s Section of Taxation and Executive Women of New Jersey, and serves as co-chair of the Women of EisnerAmper, New Jersey Chapter. She is a frequent speaker on IRS enforcement trends, the centralized partnership audit regime and its impact on pass-through entities and investors, voluntary disclosures of inadvertent tax compliance matters and related penalties, and other IRS practice, procedure, and dispute resolution topics. She also authors articles on tax controversy and legislative developments, including on refund opportunities after Kwong v. United States and changes affecting the IRS filing season.

• Experience

Miri is a Partner and National Leader of the Tax Controversy & Dispute Resolution practice at EisnerAmper, with over 20 years of IRS practice, procedure, and tax controversy experience. Prior to joining the firm, she was a Tax Controversy Principal at a Big 4 firm, and earlier in her career she served as an Attorney-Advisor at the United States Tax Court in Washington, D.C. Her practice spans tax dispute resolution; IRS practice and procedure; IRS examinations, appeals, and collections; IRS alternative dispute resolution; pre-filing agreements; private letter ruling requests; IRS voluntary disclosures; penalty abatements; refund claims and statute of limitations inquiries; and the centralized partnership audit regime.

 

Elizabeth Julia Smith, Esq., Counsel | Skadden, Arps, Slate, Meagher & Flom

Elizabeth Julia Smith is Counsel in the Tax and Tax Controversy and Litigation practices at Skadden, Arps, Slate, Meagher & Flom LLP, based in Boston. She represents clients in administrative tax disputes and litigation, advising multinational corporations, private investment firms, and individuals in connection with IRS and state audits and administrative proceedings, trial and appellate litigation in federal and state courts, and proceedings brought by non-U.S. taxing authorities. She has represented clients across a variety of industries, including health care, energy, telecommunications, private investments, transportation, and technology and her experience encompasses a wide range of complex tax issues involving income, sales, self-employment, withholding, and property taxes.

• Education & Credentials

Elizabeth earned her J.D. from Yale Law School in 2009 and her B.A., summa cum laude, from Bates College in 2003. She is admitted to practice in Massachusetts and New York.

• Recognition & Leadership

In recognition of her work, Elizabeth has been named to Chambers USA and The Best Lawyers in America, and has been repeatedly honored as one of Boston Magazine’s Top Lawyers.

• Professional Involvement

Elizabeth is an active member of the Boston Bar Association. She contributes to thought leadership on tax controversy and state and local tax matters, including publications on IRS enforcement, complex partnership structures, the limited partner exception to self-employment (SECA) tax, and the Internet Tax Freedom Act in SALT litigation, and she has participated in events such as the Tax Executives Institute New England Chapter Tax Summit and tax controversy roundtables.

• Experience

Prior to joining Skadden, Elizabeth was counsel in the tax controversy practice of another leading law firm. Her representative matters include appearing as counsel of record in Eaton Corp. & Subsidiaries v. Commissioner (U.S. Tax Court), involving significant transfer pricing issues; BankUnited, Inc. v. United States (S.D. Fla.), a tax refund case of first impression concerning Treasury Regulations under Section 597 applied to the acquisition of a failed bank; and Ivory Investment Management, LP v. Commissioner, where she obtained a full IRS concession on a statute of limitations defense for a hedge fund client defending the statutory limited partner exception to SECA tax. She achieved a complete victory in two multimillion-dollar local tax disputes for a multinational energy company involving the definitions of manufacturing and machinery one argued before the Massachusetts Supreme Judicial Court, in Veolia Energy Boston, Inc. v. Board of Assessors of Boston. She has represented multiple private equity firms and hedge funds in disputes with the IRS involving the application of SECA tax to income received by limited partners, including as counsel of record in the U.S. Tax Court for Soroban Capital Partners LP and Baker Brothers Advisors LP. Her other matters include advising a large data company in sales and income tax disputes with the Massachusetts Department of Revenue; reaching a favorable settlement for a multinational utility company in a state income tax dispute involving the addback of related-party interest; representing the purchaser of a company in litigation over its right to retain tax refunds and credits arising from CARES Act net operating loss carrybacks; advising private equity firm portfolio companies in IRS and state audits of management fees; obtaining a favorable settlement for individuals in a Massachusetts Department of Revenue dispute over responsible person liability; counseling an individual in a state court indemnification dispute arising from a potential tax liability and related IRS audit; advising multiple clients on state sales, income, and procurement tax obligations; and advising a private equity firm and its portfolio company in an internal investigation related to potential tax liabilities.

 

Kevin Spencer, Esq., Partner | White & Case

Kevin Spencer is a Partner at White & Case LLP, based in Washington, DC, and head of the firm’s Tax Controversy practice. He advises on complex tax matters on behalf of businesses, tax-exempt entities, and high-net-worth individuals, with substantial experience assisting clients in resolving disputes with the Internal Revenue Service (IRS) at the IRS Appeals and Examination/Audit divisions and at competent authority, and litigating tax disputes in federal court (the U.S. Tax Court, U.S. District Court, U.S. Court of Federal Claims, and U.S. Circuit Courts of Appeals). In addition to his tax controversy practice, he advises clients on various tax issues, including tax accounting, civil and criminal tax penalties, IRS procedures, reportable transactions, and tax shelters.

• Education & Credentials

Kevin earned his LL.M. in Taxation, with Distinction, from Georgetown University Law Center (2002); his J.D. from the University of Miami School of Law (1996); and his B.S. from Mary Washington College (1992). He is admitted to practice in the District of Columbia and Florida and speaks English and Spanish.

• Recognition & Leadership

Kevin is the head of White & Case’s Tax Controversy practice. He is a prolific writer and lecturer on a variety of tax law topics, and a recognized authority whose recent work includes contributions to the Chambers Global Practice Guides on Transfer Pricing (2026) and Tax Law and Practice—USA (2025).

• Professional Involvement

Kevin is an active speaker and author on tax controversy and procedure. His recent speaking engagements include “International Tax Disputes: How to prepare for an ever-evolving global stance” (ITR, Amsterdam, September 2025), “In-House Tax Practice – A Private Company Perspective” (TEI, New York, May 2025), “Federal Tax Controversy – Updates, Responding to IDRs, and Protests” (TEI, Carolinas, May 2025), and “How to Win Valuation Cases Before the IRS and U.S. Tax Court” (ALI, Washington, DC, March 2025). His recent publications include contributions to the Chambers Global Practice Guides and White & Case alerts and articles on IRS alternative dispute resolution, partnership tax audits, the IRS Pre-Filing Agreement Program, and SECA tax for limited partners in private equity and hedge funds.

• Experience

After earning his LL.M. in Taxation, Kevin clerked for the Honorable Robert P. Ruwe on the U.S. Tax Court. Prior to joining White & Case, he was a tax controversy partner at another international law firm. His representative litigation matters (all prior to joining White & Case) span numerous U.S. Tax Court, U.S. District Court, U.S. Court of Federal Claims, and Circuit Court proceedings, including Capital One Fin. Corp. v. Commissioner (4th Cir. 2011, affirming the Tax Court); John Hancock Life Ins. Co. v. Commissioner (141 T.C. No. 1 (2013)); Illinois Tool Works, Inc. v. Commissioner (T.C. Memo. 2018-121); Goodrich Corp. v. United States (W.D.N.C. 2012) and Goodrich Corp. v. Commissioner; Apache Corp. and Subs. v. Commissioner; Estate of Stanley F. Fulton v. Commissioner; Henry and Susan Samueli v. Commissioner; PDV Holding, Inc. v. Commissioner; multiple Growmark, Inc. and YP LLC matters; and federal claims cases including Uxbridge Solar LLC, CTC MA I, LLC, and Kleen Tech Solutions, LLC v. United States. His matters cover a broad range of issues including transfer pricing, valuation, partnership tax, self-employment (SECA) tax, energy tax credits, and IRS examination and collection disputes.

 

Katherine Jordan, Esq., Counsel | Miller & Chevalier, Chartered

Katherine Jordan is Counsel at Miller & Chevalier, where her practice centers on tax controversy and litigation. She guides clients through complex tax disputes with strategic insight and practical solutions, drawing on her strong legal writing and advocacy skills and her collaborative approach across legal, policy, and finance teams.

• Education & Credentials

Katherine earned her J.D. from the University of Virginia School of Law in 2012 and her B.A. from Duke University in 2007. She is admitted to practice in the District of Columbia and Pennsylvania, with inactive admissions in North Carolina and Ohio. Her court admissions include the United States Supreme Court, the United States Tax Court, and the United States District Court for the Western District of North Carolina.

• Recognition & Leadership

Katherine’s recognized standing in the field is reflected in her frequent media commentary and speaking engagements on emerging tax controversy issues, including AI misuse and AI-generated errors in U.S. Tax Court litigation, as quoted in Law360, Tax Notes, and Bloomberg Tax.

• Professional Involvement

Katherine contributes to the tax controversy community as a speaker and commentator. She participated in the ABA 2025 Criminal Tax Fraud and Tax Controversy Conference (December 2025), was featured on Miller & Chevalier’s tax break podcast (November 2025), and has authored firm tax alerts, including on interim guidance on the Corporate Alternative Minimum Tax (CAMT). She is frequently quoted in leading tax and legal publications on emerging issues such as the use and misuse of AI in U.S. Tax Court filings.

• Experience

Katherine began her career in estate planning for high-net-worth clients, then served as a law clerk to the Honorable Joseph W. Nega of the U.S. Tax Court (2013–2016). She subsequently practiced at a tax-focused law firm, concentrating on international and domestic tax disputes. Prior to joining Miller & Chevalier, she served as Director of Tax Controversy at a Cleveland-based real estate developer, where she oversaw all aspects of the company’s interactions with the Internal Revenue Service (IRS), including audits, administrative appeals, and litigation in federal courts such as the U.S. Tax Court, district courts, courts of appeals, and the U.S. Supreme Court.

 

Mary E. Wood, Esq., Partner | Meadows, Collier, Reed, Cousins, Crouch & Ungerman

Mary E. Wood is a Partner at Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., whose practice concentrates on resolving federal and state tax controversies, as well as white collar crime matters such as securities, tax, and bank fraud. She represents individuals, closely held businesses, and large corporations in IRS audits, appeals, and litigation in the United States Tax Court, Federal District Courts, and the United States Court of Federal Claims. Mary also represents taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies, and she represents individuals and entities in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, business torts, and other commercial disputes. Prior to joining the firm in 2006, she was a litigation associate with a Texas law firm.

• Education & Credentials

Mary earned her J.D., with honors, from the University of Texas School of Law in 2004, where she was a member of the Texas Journal of Business Law. She received her B.B.A. in Accounting from Texas A&M University in 2001. She was admitted to practice in Texas in 2004, and is admitted before the United States Tax Court, the United States Court of Federal Claims, and the United States District Courts for the Northern, Southern, Eastern, and Western Districts of Texas.

• Recognition & Leadership

Mary has been recognized in The Best Lawyers in America for Tax Law (2021–2024) and was named to D Magazine’s Best Lawyers in Dallas (2024, Tax: Litigation) as well as Best Lawyers Under 40 by D Magazine (2017). She was selected as a Texas Rising Star in Tax, as published in Texas Monthly and the Texas Super Lawyers — Rising Stars Edition (2013–2019). She is a Fellow of the American College of Tax Counsel.

• Professional Involvement

Mary is a member of the American Bar Association and the State Bar of Texas, where she serves as a Volunteer Attorney for the Section of Taxation’s Tax Court Pro Bono Program. She is also a member of the Dallas Bar Association, the Dallas Association of Young Lawyers (DAYL), the Dallas Women Lawyers Association, and Attorneys Serving the Community, and she is a Fellow of the American College of Tax Counsel. She is an active speaker and commentator on tax controversy matters, having presented at numerous national and regional programs including the NYU Tax Controversy Forum, the ABA Section of Taxation meetings, the Texas Federal Tax Institute, the Meadows Collier Annual Tax Conference, and numerous TXCPA continuing education programs. She has been a guest speaker on the Tax Notes Talk podcast (discussing Employee Retention Credit developments) and is frequently quoted in outlets such as Tax Notes, Tax Analysts, and Law360 on topics including ERC enforcement, microcaptive insurance, reportable transaction penalties, and IRS examination practice.

• Experience

Mary represents individuals, closely held businesses, and large corporations in all phases of federal tax controversy, including IRS audits, administrative appeals, and litigation before the United States Tax Court, Federal District Courts, and the United States Court of Federal Claims. Her state tax practice includes representing taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies. Beyond tax controversy, she handles white collar matters involving securities, tax, and bank fraud, and litigates commercial disputes involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, and business torts. Her notable matters include representation referenced in the Law360 report on a Texas oil driller’s $618 million IRS dispute settled in Tax Court. Before joining Meadows Collier in 2006, she practiced as a litigation associate with a Texas law firm.

 

John W. Porter, Esq., Senior Partner | Baker Botts

John W. Porter is a Partner at Baker Botts L.L.P., based in Houston, and one of the nation’s leading tax controversy attorneys, maintaining a nationwide practice representing high-net-worth individuals and businesses in sophisticated federal tax controversy matters. He has served as lead counsel for taxpayers in some of the most significant published estate and gift tax decisions of the last twenty-five years, including cases addressing formula clauses used to transfer hard-to-value assets, the application of I.R.C. § 2036 to family entities, the built-in capital gains discount when valuing stock, the “net-net gift discount,” the valuation of closely held entity interests, and the reasonable reliance defense to IRS penalties. He represents taxpayers in every aspect of the tax controversy practice — before the IRS (including examination, mediation, and appeals) and in litigation in the United States Tax Court, the United States Court of Federal Claims, the United States District Courts, and the United States Courts of Appeals — and also counsels clients on business and estate planning transactions, privilege issues, and fiduciary duty and trust and estate administration matters.

• Education & Credentials

John earned his J.D., cum laude, from Baylor Law School in 1986 and his B.B.A. in Accounting from Texas A&M University in 1982. He is Board Certified in Probate, Trust, and Estate Law by the Texas Board of Legal Specialization. He is admitted before the United States Supreme Court; the United States Courts of Appeals for the Second, Eighth, Ninth, and Eleventh Circuits; the United States Tax Court; the United States Court of Federal Claims; the United States District Courts for the Northern and Western Districts of Texas; and the United States District Court for the District of Colorado.

• Recognition & Leadership

John has been repeatedly named a Best Lawyers “Lawyer of the Year” in Houston, including for Litigation and Controversy – Tax (2024, 2019, 2015, 2012) and Litigation – Trusts and Estates (2023, 2016). He is recognized for Private Wealth Law & Disputes by Chambers High Net Worth (2016–2025), as a “Leader in the Field” for Tax Litigation by Chambers USA (2007–2011, 2014–2016), and for Wealth Management by Chambers USA (2010–2025). Chambers describes him as “widely recognized for his expertise representing clients in gift, income and estate tax matters against the IRS,” with interviewees calling him “really the leading estate and gift tax litigator in the country.” He has been listed in The Best Lawyers in America (2007–2024), recognized as a Texas Super Lawyer (2003–2024), and named to the inaugural Lawdragon 500 Leading Global Tax Lawyers. He is also a recipient of the Distinguished Accredited Estate Planner (AEP) award of the National Association of Estate Planners and Councils.

• Professional Involvement

John is a Fellow of the American College of Trust and Estate Counsel (and a former Regent) and a Fellow of the American College of Tax Counsel. He is a member of the American Bar Association’s Tax Section and Real Property, Probate and Trust Law Section, where he serves as a Supervisory Council Member and is former Chairman of the Tax, Litigation and Controversy Committee. He is a member of the Houston Bar Association and former Chairman of the State Bar of Texas Section 4-E Grievance Committee. A frequent author and presenter, he regularly speaks at the Heckerling Institute on Estate Planning, the New York University Federal Tax Institute, the Southern Federal Tax Institute, and many other programs. He served as Partner-in-Charge of the firm’s Houston office from 2014 to 2019, and is active in the community, having served on the Board of Directors of the Memorial Park Conservancy (2017–2023) as Vice Chair and Chair of the Governance Committee, and two terms on the Vestry of St. Francis Episcopal Church.

• Experience

John has served as lead counsel in many landmark estate, gift, and fiduciary cases. His significant tax cases include Estate of Anenberg v. Comm’r, 162 T.C. No. 9 (2024) (Tax Court rejected IRS argument that termination of a QTIP trust was a gift under I.R.C. § 2519); McDougall v. Comm’r, 163 T.C. No. 5 (2024); Steinberg v. Comm’r, 141 T.C. 258 (2013) (the “net, net gift”); Estate of Petter v. Comm’r, aff’d, 653 F.3d 1012 (9th Cir. 2011) (dollar-value formula clause case of first impression); Hendrix v. Comm’r, T.C. Memo 2011-133; Estate of Murphy v. United States (W.D. Ark. 2009) (obtaining a $42 million estate tax refund); Estate of Black, 133 T.C. No. 15 (2009); Estate of Christiansen v. Comm’r, aff’d, 586 F.3d 1061 (8th Cir. 2009); Estate of Jelke III v. Comm’r, 507 F.3d 1317 (11th Cir. 2007); Litman v. United States, 78 Fed. Cl. 90 (2007); Succession of McCord v. Comm’r, 461 F.3d 614 (5th Cir. 2006); Estate of Schutt v. Comm’r (2005); Estate of Bongard v. Comm’r, 124 T.C. 95 (2005); Stone v. Comm’r (2003); Dunn v. Comm’r, 301 F.3d 339 (5th Cir. 2002); Kerr v. Comm’r, 292 F.3d 490 (5th Cir. 2002); Jameson v. Comm’r, 267 F.3d 366 (5th Cir. 2001); and Davis v. Comm’r, 110 T.C. 530 (1998) (first recognition of the “unrealized capital gains discount”), among others, including representations of Roy Rogers and Dale Evans Rogers. His significant fiduciary cases include Estate of Jake Kamin, Loya v. Loya, Estate of Theodore Bauer, Kenedy Memorial Foundation v. Fernandez, 315 S.W.3d 515 (Tex. 2010), Wood v. Victoria Bank & Trust Co., 69 S.W.3d 235 (Tex. App. 2001), Farias v. Laredo National Bank, and Finley v. Laredo National Bank.

 

Kathryn Meyer, Esq., Founder & Principal Attorney | Kathryn Meyer Law, PC

Kathryn A. Meyer is the Founder and Principal Attorney of Kathryn Meyer Law PC, based in Alexandria, Virginia. She is a tax attorney with extensive experience in federal tax litigation, IRS enforcement matters, and complex tax controversy work, bringing more than 26 years of service with the Internal Revenue Service Office of Chief Counsel to her private practice. Her work today focuses on helping individuals, professionals, and businesses nationwide navigate challenging tax disputes, audits, collections, and litigation, combining deep technical knowledge with practical strategy drawn from her experience inside the government.

• Education & Credentials

Kathryn earned her J.D. from Willamette University College of Law (Class of 1998), her LL.M. from Boston University School of Law (Class of 1999), and her B.A. from the University of Southern California (Class of 1995). She was admitted to the State Bar of California in 1998 and is also licensed in the District of Columbia. She is admitted to practice before the United States Tax Court and the United States Court of Federal Claims.

• Recognition & Leadership

Kathryn’s published Tax Court opinions and media features reflect her recognized authority in tax matters. During her government career, she rose into senior IRS leadership, ultimately overseeing more than 80 attorneys and paralegals and serving as the national coordinator for Research Credit litigation.

• Professional Involvement

Kathryn has contributed to legal education as an adjunct professor at Loyola Law School and Golden Gate University. She is an active community volunteer and a frequent speaker on tax litigation topics.

• Experience

Kathryn spent approximately 26 years with the IRS Office of Chief Counsel. As an IRS attorney, she personally litigated approximately 700 cases in Tax Court, Bankruptcy Court, and District Court. Advancing into management, she trained attorneys to serve as litigators and advisors to IRS auditors and collection employees, overseeing an estimated 3,500 cases. In a subsequent senior leadership role, she oversaw more than 80 attorneys and paralegals with responsibility for an estimated 30,000 cases, and served as the national coordinator for litigation involving the Research Credit. She concluded her IRS career as the attorney to the National Taxpayer Advocate, focused on identifying and resolving taxpayer issues within the IRS. In her current practice at Kathryn Meyer Law PC, she represents individuals, professionals, and businesses in IRS disputes, audits, collections, and federal tax litigation nationwide.

 

Kelley C. Miller, Esq., Partner | Loeb & Loeb, McLean

Kelley Miller is a Partner at Loeb & Loeb LLP with nearly two decades of experience helping high net worth individuals and families navigate complex federal and state tax planning, estate and gift strategies, and federal tax controversy matters. Her clients include Fortune 500 public companies, privately held businesses, owners of closely held enterprises, family offices, and individuals with inherited wealth. She maintains extensive experience representing clients in audits and examinations before the Internal Revenue Service, including administrative appeals and litigation in federal courts—most notably the U.S. Tax Court—and her practice spans all stages of civil tax controversy at both the federal and state levels, representing corporations, partnerships, and individuals. Kelley also advises on matters at the intersection of civil and criminal tax law, has assisted clients with high-stakes matters involving the disclosure of offshore accounts and unreported income from digital assets such as cryptocurrency, and handles complex estate and gift tax litigation involving the IRS while counseling tax-exempt organizations—including private foundations and public charities—on compliance and controversy matters.

• Education & Credentials

Kelley earned her LL.M. in Taxation, with distinction, from Georgetown University Law Center, where she served as Senior Executive Editor of The Tax Lawyer. She received her J.D., cum laude, from Western New England College School of Law, where she was honored with the Dean’s Award for Outstanding Law Graduate, and she completed a Certificate in Trial Advocacy at the University of San Francisco School of Law. She holds a B.A., cum laude, from Mount Holyoke College. She is admitted to practice before the U.S. Tax Court and is a member of the bars of the District of Columbia and New Jersey.

• Recognition & Leadership

Kelley has been named a “Best Lawyer” in Tax Law (2023–2025), Litigation & Controversy—Tax (2025), and Trusts & Estates (2025) by The Best Lawyers in America. She was elected a Fellow of the American College of Tax Counsel in 2022 and was selected among Virginia Business‘ “100 People to Meet in 2022: Go Getters.” She received the Janet Spragens Pro Bono Award from the American Bar Association’s Section of Taxation in 2020, was named among Law360’s list of the “14 Influential Women in Tax Law” in 2019 and was recognized among Thompson Reuters’ “Everyday Heroes” award winners in 2016. She was also a recipient of the John S. Nolan Fellowship from the American Bar Association’s Section of Taxation (2010–2011).

• Professional Involvement

Kelley is a member of the Washington, DC Estate Planning Council and serves as an Adjunct Professor at Georgetown University Law Center and Howard University Law Center, in addition to serving as faculty for the Practising Law Institute. She is a member of the Loretta Collins Argrett Fellows Committee of the American Bar Association and sits on the Boards of Directors of the Center for Work Life Law at UC Law San Francisco (formerly UC Hastings), the Philadelphia Tax Conference, and the Advisory Committee on Passthrough Entities at Bloomberg BNA. Her prior involvement includes service as a member of Law360’s Tax Authority Federal Advisory Board (2020); Adjunct Professor positions at Temple University Beasley School of Law and Western New England College School of Law; participation in Lead Virginia (Class of 2020), the Women in Law Leadership Academy (Class of 2019), and Leadership Philadelphia (Class of 2013); and leadership roles within the American Bar Association as former Vice Chair of the Young Lawyers Liaison to the Committee on Women in the Profession, former Vice Chair of the Young Lawyers Forum of the Section of Taxation, former Chair of the National Law Student Tax Challenge Competition, and founder and former Chair and Co-Chair of the Tax Bridge to Practice Program. She is also a member of the J. Edgar Murdock Inn of Court.

• Experience

Kelley represents Fortune 500 public companies, privately held businesses, owners of closely held enterprises, family offices, and individuals with inherited wealth across complex federal and state tax matters. She has extensive experience representing clients in IRS audits and examinations, including administrative appeals and litigation in federal courts, most notably the U.S. Tax Court, and her practice covers all stages of civil tax controversy at the federal and state levels on behalf of corporations, partnerships, and individuals. She advises on matters at the intersection of civil and criminal tax law and has assisted clients with high-stakes matters involving the disclosure of offshore accounts and unreported income from digital assets such as cryptocurrency. In the estate and gift tax space, she handles complex litigation involving the IRS and advises a broad range of tax-exempt organizations—including private foundations and public charities—on both compliance and controversy matters. She also brings over 15 years of teaching experience to premier tax programs, including Georgetown University Law Center and Howard University School of Law, and is an oft-sought expert, keynote, and panelist speaker on tax law, tax policy, leadership, and women’s professional development.

 

Michel R. Stein, Esq., Principal | Hochman Salkin Toscher Perez, PC

Michel R. Stein is a principal at Hochman Salkin Toscher Perez P.C., specializing in tax controversies as well as tax planning for individuals, businesses, and corporations. For more than 25 years, he has represented individuals with sensitive-issue civil tax examinations where substantial penalty issues may arise, and has extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. He is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoid a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamlined Filing Compliance Procedures, or otherwise. Throughout his career, Mr. Stein has represented thousands of individual, business, and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters, and matters involving possible assertions of fraudulent conduct, and has defended criminal tax investigations and prosecutions at every administrative level within the IRS. He continues to provide tax advice to taxpayers and their advisors around the world.

• Education & Credentials

Mr. Stein received his LL.M. in Taxation from the NYU School of Law and earned his J.D. from the University of California, Hastings College of the Law. He also holds a B.S. in Accounting from California State University, Northridge. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court, and he is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization. He is admitted to practice before the U.S. Tax Court, the U.S. District Court for the Central and Northern Districts of California, the U.S. Court of Federal Claims, the U.S. Court of Appeals for the Ninth Circuit, and the U.S. Supreme Court.

• Recognition & Leadership

Mr. Stein is a Fellow of the American College of Tax Counsel (ACTC). He received Southern California Super Lawyer distinctions from Law & Politics, recognized and published in Los Angeles Magazine, in 2010 through 2015, 2017 through 2023, and earned the Southern California Super Lawyer Rising Star distinction in 2005, 2006, and 2007. He served as a Delegate in the 2023 Washington, D.C. Delegation of the California Lawyers Association, authoring a paper on proposed changes to the computation of the imputed underpayment under the BBA partnership audit regime pursuant to IRC §6225(b). He has held numerous leadership positions, including Past-Chair of the State Bar of California Tax Procedure & Litigation Committee, Past-Chair of the State Bar of California Tax Law Advisory Commission of the Board of Legal Specialization, Past-Chair of the State Bar of California Young Tax Lawyers Committee, and Past-Chair of the L.A. County Bar Association Young Tax Lawyers Committee.

• Professional Involvement

Mr. Stein is a Fellow of the American College of Tax Counsel and a member of the Association of Tax Counsel, Los Angeles. He is involved with the American Bar Association Taxation Section, the California State Bar Association Taxation Section, the Beverly Hills Bar Association Taxation Section, and the Los Angeles County Bar Association Taxation Section. He has served as an Adjunct Professor at Golden Gate University, Graduate School of Taxation, and as an Instructor on Estate Planning and Probate in the UCLA Attorney Assistant Training Program. He is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, and state and federal worker classification issues, and he has extensively published and co-authored articles in the field of tax law in outlets such as the CCH Journal of Tax Practice and Procedure, Financier, Best Lawyers, and the USC Gould School of Law’s Major Tax Planning editions, addressing subjects including FBAR enforcement, cryptocurrency reporting, and international tax compliance.

• Experience

Mr. Stein has represented thousands of individual, business, and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters, and matters involving possible assertions of fraudulent conduct, and has defended criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. His practice emphasizes sensitive-issue civil tax examinations involving substantial penalty exposure and foreign and domestic voluntary disclosures concerning foreign account and asset compliance, and he has guided hundreds of individuals into compliance with their foreign reporting requirements through the OVDP, Streamlined Filing Compliance Procedures, or otherwise. He routinely advises and defends clients in matters involving California residency, digital assets and cryptocurrency investigations, high-net-worth taxpayer compliance and examination, domestic and international tax compliance, challenges to listed and reportable transactions, partnership tax and audit rules, employment tax and worker classification issues, and tax controversies arising from complex real
estate and business transactions. He began his legal career as an Attorney-Adviser to Special Trial Judge Larry L. Nameroff of the U.S. Tax Court.

 

Michelle Abroms Levin, Esq., Shareholder | Dentons

Michelle Abroms Levin is a shareholder in Dentons Sirote’s Huntsville, Alabama office, where she is a member of the Tax practice group and manages the Huntsville office. She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, federal district court, and the Courts of Appeals. Michelle has secured major victories for her clients in the Eleventh Circuit, Fifth Circuit, and Tax Court, elevating important Administrative Procedure Act issues in the tax controversy context, and her experience includes a wide range of complex tax issues. She also counsels clients in tax and business planning, working with them to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels. Prior to joining Dentons Sirote (formerly Sirote & Permutt, PC), Michelle worked as a trial attorney at the Tax Division of the U.S. Department of Justice, where she represented the United States in federal district court.

• Education & Credentials

Michelle earned her J.D. from The University of Texas, graduating in 2005, and holds a BSBA from the Olin Business School at Washington University in St. Louis, which she received in 2002. She is admitted to practice in Alabama (Alabama State Bar).

• Recognition & Leadership

Michelle was elected a Fellow of the American College of Tax Counsel (ACTC). She has been recognized in The Best Lawyers in America for Litigation and Controversy – Tax, with recognition reflected through the 2026 edition (recognized in Best Lawyers since 2023). She received the WomenLEAD Excellence Award in the “Emerging Leader” category during Dentons’ annual International Women’s Day celebration

• Professional Involvement

Michelle manages Dentons Sirote’s Huntsville office and is a member of the firm’s Tax practice group, having also been associated with the firm’s Tax Controversy and Conservation Easement groups. She is an active author and contributor on federal tax controversy topics, regularly publishing through Dentons’ US Tax Disputes platform alongside colleagues including Gregory Rhodes, Mark A. Loyd, Bailey Roese, Helen Cooper, and others, on subjects such as the U.S. Supreme Court’s overturning of Chevron deference and its impact on tax matters.

• Experience

Michelle represents clients during all phases of federal income tax controversies, including IRS audits, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, federal district court, and the Courts of Appeals. She has secured major victories in the Eleventh Circuit, Fifth Circuit, and Tax Court, advancing significant Administrative Procedure Act issues in the tax controversy context, and her practice encompasses a wide range of complex tax issues including conservation easement and charitable contribution matters. She also counsels clients on tax and business planning, structuring transactions to maximize tax benefits, reduce risk, and comply with tax law at the local, state, and federal levels. Earlier in her career, she served as a trial attorney with the Tax Division of the U.S. Department of Justice, representing the United States in federal district court.

 

Melissa L. Wiley, Esq., Partner | Kostelanetz

Melissa Wiley is a Partner at Kostelanetz LLP with more than 20 years of experience in tax law, having represented a diverse range of clients—from large corporations to high-net-worth individuals—in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, she excels at distilling intricate tax issues into clear, actionable insights, helping clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Melissa serves as a trusted advisor to clients at all levels of administrative tax controversy, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility, and she has significant experience handling penalty and international information reporting matters. When an administrative resolution cannot be reached, she is well-equipped to litigate, and she also represents clients facing government and third-party subpoenas and investigations while frequently advising on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa pairs a scrupulous, detail-oriented approach with a thorough understanding of how tax affects her clients’ financial affairs, and her background in statistics and the insurance industry has fostered a natural ability to collaborate effectively with technical and forensic experts.

• Education & Credentials

Melissa received her J.D., cum laude, from the Georgetown University Law Center in 2003, and earned her B.S. in Actuarial Science, summa cum laude and as valedictorian, from The College of Insurance in 1998. She is admitted to practice in the District of Columbia, New York, and Virginia, as well as before the U.S. Tax Court, the Court of Federal Claims, the U.S. Court of Appeals for the Eleventh Circuit, and the U.S. District Court for the District of Columbia.

• Recognition & Leadership

Melissa is a Fellow of the American College of Tax Counsel (since May 2019) and serves as its Regent for the Federal Circuit (since March 2023). She is a member of the J. Edgar Murdock Inn of Court. Within the ABA Section of Taxation, she serves as Vice Chair for Membership, Diversity and Inclusion (since August 2024) and Chair of the Loretta Collins Argrett Fellowship Committee, and she was named a Nolan Fellow in 2011. She is recognized for her in-depth knowledge of tax controversy topics and frequently speaks on IRS filing requirements, enforcement priorities, penalties, ethics, and the Corporate Transparency Act.

• Professional Involvement

Melissa is deeply engaged in the tax community across multiple organizations. Within the ABA Section of Taxation, in addition to her current leadership roles, she has served as Vice-Chair of the Appointments to the Tax Court Committee, Vice Chair of Committee Operations (2020–2022), a Council Member (2016–2019), and former Chair of both the Young Lawyer’s Forum and the Law Student Tax Challenge. At the AICPA, she has been a member of the IRS Advocacy and Relations Committee since January 2019, currently serving as its Chair (since May 2024) after serving as Vice-Chair (2023–2024), and is a member of the National Tax Conference Committee. She chaired the DC Bar Association Tax Section’s Tax Audits and Litigation Committee (2022–2024) after serving as its Vice-Chair (2020–2022). She also serves as an adjunct professor at her alma mater, Georgetown University Law Center, where she will teach an upcoming course on Tax Research and Writing. Her pro bono and community service includes board service with the Community Tax Law Project (since November 2022) and more than 15 years with the Children’s Law Center, where she has served on the Board of Directors, as Treasurer, and on its Emeritus Board, offering pro bono assistance in custody and abuse/neglect cases.

• Experience

Melissa represents corporate, institutional, and individual clients in tax controversy matters in litigation and before all levels of the IRS, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility. She has significant experience handling penalty and international information reporting matters, and her litigation experience spans the U.S. Tax Court, the Court of Federal Claims, and various federal district courts. She also represents clients facing government and third-party subpoenas and investigations and counsels clients on voluntary disclosures of prior tax noncompliance. Her practice is informed by six years as an Assistant General Counsel at a Big Four accounting firm, which gave her a deep understanding of the regulations and professional standards governing tax practice, as well as her earlier background as an actuary in statistics and the insurance industry.

 

Aaron Esman, Esq., Member | Ziering & Esman

Aaron M. Esman is an accomplished tax controversy and litigation attorney based in New York who represents individual and entity taxpayers before the Internal Revenue Service, the Department of Justice, and state and local taxing authorities. He represents taxpayers in all stages of tax controversy, including audits, appeals, and litigation, and he also advises clients on tax matters related to corporate transactions, mergers and acquisitions, compliance, and corporate governance. An active member of the American Bar Association Section of Taxation—where he serves as Chair of the Standards of Tax Practice Committee and Vice-Chair of the LGBTQ+ Lawyers in Tax Forum—Aaron is regularly asked to speak on tax matters for both tax and non-tax audiences and has moderated a series of panels alongside staff from the Internal Revenue Service. A proud supporter of the arts who can often be found at one of New York City’s great theaters, he also serves on the Alumni Board of Directors for the University of Miami.

• Education & Credentials

Aaron earned his LL.M. in Taxation from the New York University School of Law and his Juris Doctor from Emory University School of Law in Atlanta, Georgia, where his honors included serving as Executive Managing Editor of the Emory Corporate Governance and Accountability Review, membership in the Emory Moot Court Society, induction into the Order of the Barristers, and earning the Transactional Law and Skills Certificate. He completed his undergraduate studies at the University of Miami in Coral Gables, Florida, earning a Bachelor of Business Administration and a Bachelor of Science in Communications. He is admitted to practice in New York, New Jersey, and the District of Columbia, as well as before the Supreme Court of the United States, the United States Tax Court, the United States Court of Federal Claims, the U.S. District Courts for the Southern, Eastern, and Western Districts of New York, and the Northern District of Illinois.

• Recognition & Leadership

Aaron was named a John S. Nolan Fellow of the American Bar Association Section of Taxation (2022–2023). He has been recognized by Best Lawyers as “Ones to Watch in America” in Corporate Law (2024–present) and Litigation & Controversy – Tax (2024–present), and in Tax Law (2026). He has also been selected as a Super Lawyers New York Rising Star (2018–present). Within the ABA Section of Taxation, he currently serves as Chair of the Standards of Tax Practice Committee and Vice-Chair of the LGBTQ+ Lawyers in Tax Forum, having previously served as Vice-Chair of the Standards of Tax Practice Committee (2023–2025).

• Professional Involvement

Aaron is a member of the American Bar Association Section of Taxation, where his leadership roles include Chair of the Standards of Tax Practice Committee, Vice-Chair of the LGBTQ+ Lawyers in Tax Forum, and former Vice-Chair of the Standards of Tax Practice Committee (2023–2025). He served as an Adopt-A-Base VITA Training Program Instructor at West Point Military Academy and Fort Hamilton (2017–2021). He is active with the University of Miami, serving on its Alumni Board of Directors, as a member of the Alumni Council (2021–2025), and as President of LGBTQ+ Canes (2023–2025). He is also a frequent author and speaker, with published works appearing in Bloomberg Tax, Law360, the Tax Management Portfolio, and the Emory Corporate Governance and Accountability Review on subjects including the partnership audit regime and partnership representatives, and he has presented at numerous national programs including the NYU Tax Controversy Forum, the New York Law School Annual Tax Lawyering Workshop, and recurring ABA Section of Taxation meetings on tax controversy, ethics, AI in tax practice, and post-Loper Bright tax guidance.

• Experience

Aaron represents individual and entity taxpayers before the Internal Revenue Service, the Department of Justice, and state and local taxing authorities, handling all stages of tax controversy, including audits, appeals, and litigation. In addition to his controversy and litigation practice, he advises clients on tax matters related to corporate transactions, mergers and acquisitions, compliance, and corporate governance. His courtroom admissions span the U.S. Tax Court, the U.S. Court of Federal Claims, multiple federal district courts, and the Supreme Court of the United States. He has moderated panels alongside Internal Revenue Service staff and is regularly invited to speak on tax matters before both tax and non-tax audiences.

 

Josh O. Ungerman, Esq., CPA, Partner | Meadows, Collier, Reed, Cousins, Crouch & Ungerman

Josh O. Ungerman is a partner at Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., whose experience as a former IRS Senior Trial Attorney and Department of Justice Special Assistant U.S. Attorney is invaluable in helping clients with IRS civil tax and criminal tax controversy matters at all levels, along with tax and estate planning. The tax and estate matters in which Josh is involved are typically very complex from both a factual and legal perspective and often require both legal and accounting skills—Josh is also a Certified Public Accountant. He is engaged in defending taxpayers and issues against IRS inquiries and actions, with an IRS defense practice that covers civil and criminal exams, investigations, and trials, and many of his tax controversy matters include an offshore component. He is frequently called upon to remediate non-compliant offshore structures and advise on offshore compliance requirements, and he works with families on wealth preservation and transfer strategies. Josh is a frequent speaker on tax topics including domestic and offshore IRS exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, and state tax controversy issues.

• Education & Credentials

Josh earned his J.D. from Southern Methodist University School of Law in 1990, where he served on the Board of Editors of the Southwestern Law Journal, and received his B.B.A. from the University of Texas at Austin in 1987. He is a Certified Public Accountant and was admitted to practice in Texas in 1990.

• Recognition & Leadership

Josh has been recognized by The Best Lawyers in America as the 2023 Litigation and Controversy – Tax Law “Lawyer of the Year” in the Dallas/Fort Worth area, and has been listed in The Best Lawyers in America for Litigation and Controversy – Tax and Tax Law from 2015 through 2025. He was selected to the Texas Super Lawyers Top 100 Lawyers in Texas list (2017) and has been named to Texas Super Lawyers – Tax in Texas Monthly from 2003 through 2024. He was named to Best Lawyers in D Magazine’s Hall of Fame (2022, Tax: Litigation), recognized as a Best Lawyer in Dallas by D Magazine across numerous years, named a Best Business Lawyer by D Magazine (2009, Tax), and a Best Lawyer Under 40 by D Magazine (2004 and 2005). In 2013 he was named a Top Rated Lawyer in White Collar Criminal Defense Law by ALM. He received a five-year appointment to the American Bar Association Section of Taxation’s Committee on Appointments to the Tax Court (ending June 30, 2023) and has been recognized by ITR World Tax.

• Professional Involvement

Josh is a Fellow of the American College of Tax Counsel. Within the Dallas Bar Association he is Past Chair of the Tax Section, and within the State Bar of Texas he is Past Chair of the Tax Controversy Committee. In the American Bar Association Section of Taxation, he served as a member of the Appointments to the Tax Court Committee (2015–2017), Past Chair of the Civil and Criminal Tax Penalties Committee, and Past Chair of the IRS Investigations and Practices Subcommittee on Civil and Criminal Tax Penalties. He is a member of the American Institute of Certified Public Accountants, the Texas Society of Certified Public Accountants, and the Dallas CPA Society (Tax Committee). He has served as a Planning Committee Member for the New York University School of Continuing and Professional Studies’ 2nd Annual Tax Controversy Forum and for the UCLA Extension’s 25th Annual Tax Controversy Institute. A prolific author and speaker, he has published in outlets including the Journal of Tax Practice & Procedure, the Texas Tax Lawyer, Dallas Bar Association Headnotes, and The Practical Tax Lawyer, and has been quoted extensively in the Wall Street Journal, Bloomberg Law, and Tax Notes on subjects such as FBAR penalties, offshore compliance, and IRS enforcement.

• Experience

Josh defends taxpayers against IRS inquiries and actions across civil and criminal exams, investigations, and trials, with deep concentration in IRS civil and criminal tax controversy matters that frequently carry an offshore component, as well as tax and estate planning and wealth preservation and transfer strategies for families. He is regularly engaged to remediate non-compliant offshore structures and advise on offshore compliance requirements. Prior to joining the firm in 1994, he was a civil prosecutor for the Internal Revenue Service in the Dallas District Counsel office and a Special Assistant United States Attorney for the Department of Justice in Dallas during that time. Earlier, he served as a law clerk to the Honorable Carolyn M. Parr at the United States Tax Court in Washington, D.C.

 

Joshua Wu, Esq., Deputy Assistant Attorney General for the Tax Litigation Branch | US Department of Justice, Civil Division

Joshua Wu serves as the Deputy Assistant Attorney General for the Tax Litigation Branch of the Civil Division of the U.S. Department of Justice, a role he has held since 2025. He rejoined the Department from Latham & Watkins LLP in Washington, D.C., where he practiced in the firm’s tax controversy and litigation group, counseling and advocating for companies and high-net-worth individuals on all aspects of tax controversies and litigation. He previously served at the Department from 2019 to 2021 as Deputy Assistant Attorney General for Appellate and Review in the Tax Division, where he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. In that role he also represented the United States in appellate oral arguments, evaluated and approved significant civil settlement offers, furnished advice to the Tax Division’s trial sections in complex tax cases, led the operational functions of the Tax Division, and led the Office of Legislation and Policy, which works with the Department of the Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives.

• Education & Credentials

Josh earned his LL.M. in Taxation from the Georgetown University Law Center. He is a graduate of the Syracuse University College of Law and the University of Virginia.

• Recognition & Leadership

In October 2024, Josh was inducted as a Fellow of the American College of Tax Counsel, a nonprofit association of tax attorneys recognized for excellence in tax practice and substantial contributions to the legal profession. Election as a Fellow requires nomination by a current Fellow and evaluation by a committee of the College’s Board of Regents, with membership criteria including bar membership in one or more states for at least 15 years, a career principally devoted to tax law and tax-related matters, and a demonstrated high standard of excellence and ethical conduct in the practice of tax law. He has also been identified by Legal 500 as a key practitioner within Latham & Watkins’ contentious tax practice.

• Professional Involvement

In private practice, Josh advised large companies and high-net-worth individuals on all aspects of federal tax law and controversies, with a practice focused on litigating high-stakes tax cases and representing clients in both civil and criminal tax controversy matters. His advisory work spans tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, transfer pricing, and tax-exempt controversies. He has served as a featured speaker on tax matters, including on voluntary disclosure programs and the Section 199A pass-through deduction, and has presented before professional audiences such as CPA societies and international tax symposia.

• Experience

Joshua Wu serves as the Deputy Assistant Attorney General for the Tax Litigation Branch of the Civil Division (2025–Present), one of seven deputy assistant attorneys general in the Civil Division reporting to the Assistant Attorney General. Immediately before this role, he was counsel in the Tax Department and a member of the Tax Controversy Practice at Latham & Watkins LLP in Washington, D.C., where he advised companies, tax-exempt organizations, and high-net-worth individuals on resolving contentious tax matters. From 2019 to 2021, he served at the Department of Justice as Deputy Assistant Attorney General for Appellate and Review in the Tax Division, overseeing civil federal tax appeals nationwide, managing a 40-lawyer team, arguing appeals on behalf of the United States, approving significant civil settlements, advising the Tax Division’s trial sections, and leading the Office of Legislation and Policy. Earlier in his career he worked as an associate at Latham & Watkins and as a partner at a large international law firm.

 

Don Fort, CPA, Senior Investigator | Kostelanetz

John D. (Don) Fort is a Senior Investigator at Kostelanetz LLP and the former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and an extensive network of connections both within the government and in private industry. At the firm, he assists clients facing governmental investigations involving all manner of alleged financial and economic crimes, including tax controversies or suspected tax crimes, money laundering, and Bank Secrecy Act violations, with particular expertise in investigations involving cryptocurrency and cannabis-related matters. He also conducts internal investigations, advises clients on compliance regimes, and is available as an expert witness and litigation consultant and for voluntary or court-mandated monitorships. Don currently provides his leadership and law enforcement expertise to the advisory boards of several fintech, anti-money laundering compliance, cryptocurrency, and cannabis compliance companies, including AML RightSource, ZenLedger, and NCS Analytics, and serves as Chief Business Officer with IVIX.

• Education & Credentials

Don holds a Bachelor of Arts degree in Management from Gettysburg College (1990) and is a licensed Certified Public Accountant in the State of Virginia.

• Recognition & Leadership

In 2020, Don was the recipient of the Association of Certified Anti-Money Laundering Specialists (ACAMS) Public-Private Partnership Award. As Chief of IRS-CI from 2017 to 2020, he led the sixth-largest U.S. law enforcement agency, managing a budget of over $625 million and a worldwide staff of approximately 3,000, including 2,100 special agents across 21 IRS field offices and 11 foreign countries. As both Chief and Deputy Chief, he oversaw numerous high-profile matters, including the “Varsity Blues” college admissions scandal; the Paul Manafort, Michael Cohen, and Michael Avenatti federal tax investigations; the takedown of the largest darknet child exploitation website funded by cryptocurrency; the prosecution of two Chinese nationals charged with laundering $100 million in a cryptocurrency exchange hack; the Swiss Bank Program, in which 80 Swiss banks entered agreements and paid $1.36 billion in penalties; the FIFA worldwide money laundering, structuring, and tax evasion matter; and the Credit Suisse guilty plea.

• Professional Involvement

Don is an accomplished public speaker who serves as an expert in law enforcement, leadership, financial crimes, and enhancing public-private partnerships. He has extensive experience briefing high-level government officials, has testified before Congress, and has provided numerous briefings to congressional staff. He serves on the advisory boards of several fintech, anti-money laundering, cryptocurrency, and cannabis compliance companies, including AML RightSource, ZenLedger, and NCS Analytics, and holds the role of Chief Business Officer at IVIX. He participates regularly in leading tax and economic crime programs, including the ABA Criminal Tax Fraud and Tax Controversy meeting, the Hawaii Tax Institute, and the Cambridge International Symposium on Economic Crime.

• Experience

Don served with the U.S. Department of the Treasury, Internal Revenue Service, Criminal Investigation (IRS-CI) from August 1991 to September 2020, spending the final nine years as a member of the Senior Executive Service. He began as a Special Agent in the Washington, D.C. Field Office (1991–1999), then served as Supervisory Special Agent in Orlando (1999–2003); Section Director/Senior Analyst for Special Investigative Techniques in Washington, D.C. (2003–2006); Assistant Special Agent in Charge of the Baltimore and Washington, D.C. Field Offices (2006–2009); Special Agent in Charge of the Philadelphia Field Office (2009–2010); Deputy Director of Strategy at Washington, D.C. Headquarters (2010–2011); Director of Field Operations for the Western and Northern Areas (2011–2014); Deputy Chief of IRS-CI (2014–2017); and Chief of IRS-CI (2017–2020). His tenure included oversight of investigations into some of the most significant financial crimes involving tax evasion, sanctions evasion, money laundering, bribery, international corruption, bank malfeasance, cyber and cryptocurrency crimes, and terrorist financing. Since leaving government in 2020, he has served as Director of Investigations and now Senior Investigator at Kostelanetz LLP, operating out of the firm’s Washington, D.C. office.

 

Guy Ficco, CFE, Senior Investigator | Kostelanetz

Guy Ficco is a Senior Investigator at Kostelanetz LLP and the immediate past Chief of IRS Criminal Investigation (IRS-CI). As Chief and Deputy Chief of IRS-CI from 2022 through April 2026, Guy directed one of America’s largest federal law enforcement organizations, overseeing operations with an annual budget exceeding $1 billion and leading a global workforce of approximately 3,500 personnel, including more than 2,300 special agents deployed across 20 domestic field offices and operations in 14 international locations. Throughout his law enforcement career, he spearheaded investigations into major financial crimes spanning tax evasion, sanctions violations, money laundering, corruption, banking misconduct, cybercrime, cryptocurrency offenses, and terrorism financing. At the firm, he draws on more than 30 years of federal law enforcement experience to advise clients on matters including criminal tax exposure, parallel civil-criminal investigations, Bank Secrecy Act and anti-money laundering issues, cryptocurrency enforcement, corporate compliance, and cross-border financial crime.

• Education & Credentials

Guy earned his Bachelor of Business Administration degree, with a concentration in accounting, from Dominican University (New York). He is a Certified Fraud Examiner and maintains professional memberships in both the Association of Certified Fraud Examiners (CFE) and the Association of Certified Sanctions Specialists.

• Recognition & Leadership

During Guy’s tenure, IRS-CI achieved record enforcement results, expanded its international footprint, and strengthened collaboration with domestic and foreign law enforcement agencies. In his roles as both Chief and Deputy Chief, he directed several landmark investigations, including Janet Mello’s $100 million grant fraud scheme, a $1 billion syndicated conservation easement tax fraud conspiracy, the comprehensive $1 billion Bank Secrecy Act and IEEPA investigation of Binance, a major biofuel tax conspiracy, and multiple prominent darknet marketplace cases involving narcotics trafficking, cybercrime, identity theft, and child exploitation materials. He co-chaired the Treasury Department’s Fentanyl Strike Force and led IRS-CI’s participation in the United States’ “Task Force KleptoCapture” following Russia’s invasion of Ukraine. His international leadership roles included serving on the Executive Policy Board for the International Law Enforcement Academy (ILEA), active participation in the OECD Task Force on Tax Crimes and Other Crimes (TFTC), and chairing the OECD Tax Crimes Enforcement Network (TCEN). He also represented the United States as Chief of IRS-CI as part of the Joint Chiefs of Global Tax Enforcement (J5).

• Professional Involvement

As an established expert in financial crime enforcement, Guy regularly addresses domestic and international audiences on complex white-collar fraud, cryptocurrency investigations, and anti-money laundering compliance. Under his leadership, IRS-CI launched an innovative Public-Private Partnership initiative (CI FIRST) designed to foster collaboration between law enforcement and Bank Secrecy Act filers, including financial institutions, casinos, and money service businesses. He championed a data-driven transformation within IRS-CI, cultivating a new generation of analytically minded leaders and introducing innovations such as an artificial intelligence tool that assesses prosecution likelihood during investigation initiation phases. He completed a congressional fellowship with the Permanent Subcommittee on Investigations for Homeland Security and Governmental Affairs, contributing to oversight investigations examining international tax shelters, corporate stock option abuses, and credit card fraud, and he has regularly briefed senior government officials and congressional staff on critical matters. He maintains memberships in the Association of Certified Fraud Examiners and the Association of Certified Sanctions Specialists.

• Experience

Guy began his IRS career in 1995 as a Special Agent in New York, progressively advancing through various supervisory positions before joining the Senior Executive Service in May 2020 as Executive Director of Global Operations, a role he held until his appointment as Deputy Chief in July 2022. He subsequently served as Chief of IRS-CI, leading the agency through April 2026. Across his career he held a range of CI leadership roles, including Special Agent in Charge of the Philadelphia Field Office (2018–2020), Supervisory Special Agent in the Washington Field Office, and senior analyst and executive positions spanning financial crimes, international operations, and global policy and support. During his tenure as Chief and Deputy Chief, he oversaw the agency’s worldwide enforcement operations and directed many of its most consequential domestic and cross-border criminal tax and financial crime investigations. Since leaving government in 2026, he has served as a Senior Investigator at Kostelanetz LLP.

 

Jarod Koopman, Chief, Criminal Investigation Division; Chief Tax Compliance Officer | Internal Revenue Service

Jarod Koopman is the Chief of IRS Criminal Investigation (IRS-CI) and the agency’s Chief Tax Compliance Officer. He stepped into the Chief role after more than 26 years with the IRS, including over two decades within IRS-CI, where he has held leadership positions at multiple levels. As Chief of IRS-CI, he leads a global workforce of approximately 3,000 personnel, including more than 2,100 special agents operating across 20 field offices and 11 international locations. As Chief Tax Compliance Officer, he oversees IRS compliance operations across several major divisions and offices, including the Large Business and International division, the Small Business/Self-Employed division, the Tax Exempt and Government Entities division, IRS Criminal Investigation, the Office of Professional Responsibility, the Return Preparer Office, and the Whistleblower Office. He is widely respected as a global leader in cryptocurrency tracing and dark web investigations.

• Education & Credentials

A native of Upstate New York, Jarod is a graduate of Nazareth University in Rochester. He began his law enforcement career in 2002 following his training at the Federal Law Enforcement Training Center (FLETC), excelling in both FLETC’s Criminal Investigator Training Program and IRS-CI’s Special Agent Basic Training Program and graduating at the top of his class.

• Recognition & Leadership

Under Jarod’s leadership, IRS-CI significantly enhanced its capabilities, establishing itself as a global leader in cryptocurrency tracing and dark web investigations. As director of cybercrime for IRS-CI, he helped achieve major wins against crimes involving cryptocurrency, including the dismantling of the Silk Road dark web marketplace, which led to the government seizing $3.36 billion worth of bitcoin. In 2011 he was selected for the Accelerated Senior Leadership Program (ASLP). Upon his appointment as Chief, IRS-CI publicly recognized that over his then-26-year career he had established himself as a leader and innovator within the agency. His work has also been recognized in the bestselling book Who Is Government? by Michael Lewis and featured in the Washington Post series “Cyber Sleuth.”

• Professional Involvement

Jarod is recognized as an expert on financial crime, cryptocurrency tracing, and anti-money laundering enforcement, and he addresses law enforcement and compliance audiences on these topics, including as a speaker at the 2026 West Coast Anti-Money Laundering (WCAML) Forum. In 2015, he was tasked with establishing and leading IRS-CI’s Cyber Crimes and Cyber and Forensics Services sections, serving as Director of both. Earlier in his career, after transitioning to IRS Headquarters as a Senior Analyst, he worked under the direction of the National Identity Theft Coordinator, contributing to the agency’s heightened focus on identity theft as a national priority in 2012.

• Experience

Jarod began his law enforcement career with the IRS in 2002 as a special agent in Rochester, New York. In April 2010, he was promoted to Supervisory Special Agent for the Western District of New York, and the following year he was selected for the Accelerated Senior Leadership Program and transitioned to IRS Headquarters as a Senior Analyst, working under the National Identity Theft Coordinator. Beginning in 2015–2016 as a CI executive, he led the creation and development of both the Cyber Crimes and Cyber and Forensics Services sections, serving as Director of each. He later served as Assistant Special Agent in Charge of the Chicago Field Office, then as Special Agent in Charge of the Detroit Field Office, and as Executive Director of Northern Field Operations, overseeing criminal investigative activities across 17 states. In October 2025 he was named Acting Chief Tax Compliance Officer, overseeing the agency’s enforcement divisions, and effective April 2026 he was named Chief of IRS Criminal Investigation while continuing to serve as Chief Tax Compliance Officer.

 

Karen E. Kelly, Esq., Partner | Kostelanetz

Karen Kelly is a Partner in the Washington, D.C. office of Kostelanetz LLP and the former head of the Justice Department’s Tax Division. She joined the firm after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations involving criminal tax and white-collar matters and against state and federal criminal charges, conducting internal investigations, representing legal and tax professionals and their firms in license and regulatory matters, and complex civil and criminal litigation. She most recently served at the Department of Justice as the Acting Assistant Attorney General and delegated component head of the Tax Division, where she supervised all federal civil and criminal tax matters assigned to the Department throughout the country, along with more than 300 trial and appellate attorneys. First and foremost a litigator, Karen led and managed hundreds of sophisticated grand jury investigations and criminal tax jury trials in federal district courts nationwide.

• Education & Credentials

Karen received her law degree, cum laude, from Syracuse University College of Law and her bachelor’s degree from the College of the Holy Cross. She is admitted to practice in the District of Columbia and the Eastern District of Virginia.

• Recognition & Leadership

Karen received numerous commendations recognizing her extraordinary government service. She was twice honored with the Department of Justice Attorney General’s Award — among the highest service awards issued by the Department — including the Attorney General’s Award for Outstanding Service (2014) and the Attorney General’s Distinguished Service Award (2011) for her contributions as a member of a public corruption task force. She received the IRS Criminal Investigation Chief’s Award (2007) for her successful prosecution of a telecommunications entrepreneur who evaded more than $200 million in taxes — the largest individual income tax evasion case at the time — as well as the Department of Justice Executive Office Director’s Award for Superior Performance in Litigation (2009). She has been the recipient of more than a dozen Tax Division Outstanding Attorney Awards (2000, 2002, and 2005 through 2018), the Department of Justice Outstanding Mentor Award (2010), and the United States Attorney’s Office for the District of Columbia Outstanding Merit recognition (2003).

• Professional Involvement

Karen is a member of the American Bar Association (Section of Taxation; White Collar and Criminal Litigation), the National Association of Criminal Defense Attorneys (Lawyers), the Virginia State Bar (Section of Taxation; Litigation), and the Virginia Women’s Attorney Association. She currently serves on the Virginia State Bar Disciplinary Committee, reviewing attorney disciplinary complaints and investigations and conducting disciplinary hearings, having also served on the Committee from 2014 through 2018. A frequent lecturer, she has presented at U.S. Attorneys’ Offices on tax crimes, grand jury investigations, trial practice, and prosecutions, and as part of her government service she trained dozens of attorneys, law enforcement agents, and IRS personnel in the United States and abroad — including at the Justice Department’s training center in South Carolina, at IRS Field Offices, and in international engagements with Serbian law enforcement and the Barbados Revenue Authority. She regularly speaks on tax enforcement issues at ABA-sponsored conferences and other tax bar events.

• Experience

Karen served with the Tax Division of the U.S. Department of Justice in Washington, D.C., as Delegated Component Head and Acting Deputy Assistant Attorney General (2025), Chief of the Southern Criminal Enforcement Section (2019–2025), Assistant Chief of the Northern Criminal Enforcement Section (2008–2019), and Trial Attorney in the Northern Criminal Enforcement Section (1997–2008). During her career as a federal prosecutor she handled crimes including tax evasion, conspiracy, payroll tax fraud, obstruction, money laundering, FBAR violations, false claims, nominee entities, identity theft, false tax filings, and complex tax shelters, and she assisted with the Department’s Swiss Bank Program and resolved complex offshore entity investigations. As Assistant Chief and later Chief, she worked with federal prosecutors in more than 40 U.S. Attorneys’ Offices, coordinated and managed the Tax Division criminal portfolio, and built a strong working relationship with IRS Criminal Investigation; her successes include the first successful criminal prosecution of multiple professionals involved in the creation and promotion of a syndicated conservation easement tax shelter. She also served as a Special Assistant U.S. Attorney in the Southern District of New York (white-collar prosecutions) and in the Southern District of California (immigration and narcotics crimes), and earlier prosecuted state crime as an Assistant Commonwealth’s Attorney in Fairfax County, Virginia (1994–1997). Since 2025, she has practiced as a Partner at Kostelanetz LLP.

 

Scott Levine, Esq., Partner | Baker McKenzie

Scott Levine is a partner in Baker McKenzie’s Tax Practice Group, based in the Firm’s Washington, D.C. office. Prior to joining the Firm, Scott most recently served as the Deputy Assistant Secretary (International Tax Affairs) in the U.S. Department of the Treasury, where he led the Office of Tax Policy’s work on international affairs, including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2. He has significant experience advising multinational companies on the tax aspects of corporate transactions, including cross-border and domestic mergers and acquisitions, spin-offs and other divestitures, restructurings, financing, and joint ventures, and he has negotiated private letter rulings with the Internal Revenue Service in the corporate, international, financial instruments, and energy tax credit areas.

• Education & Credentials

Scott earned his J.D. from American University (1997) and his B.A., cum laude with distinction, from the University of Pennsylvania (1994). He is admitted to practice in the District of Columbia (2006) and Florida (1997).

• Recognition & Leadership

Scott is a Fellow of the American College of Tax Counsel and is ranked in Chambers USA. He has been recognized in The Best Lawyers in America for Tax Law and named among Washingtonian Magazine’s Washington’s Top Lawyers (Tax). He received the Distinguished Service Award from the U.S. Department of the Treasury and was the inaugural recipient of the DC Bar’s Trailblazer Award for the Taxation Community.

• Professional Involvement

Scott is a member of the ABA Tax Section Nominating Committee and is the former Chair of the ABA Corporate Tax Committee. Within the DC Bar, he serves as Chair of the Annual Tax Legislative and Regulatory Update Conference and previously served as Chair of the Tax Section Corporate Tax Committee and as a two-term member of the Tax Section Steering Committee. He is an active author and commentator on international and corporate tax developments, including the OECD Model Tax Convention, Pillar Two, and recent U.S. tax legislation.

• Experience

Scott advises multinational companies on the tax aspects of corporate transactions, including cross-border and domestic mergers and acquisitions, spin-offs and other divestitures, restructurings, financing, and joint ventures, and he negotiates private letter rulings with the IRS in the corporate, international, financial instruments, and energy tax credit areas. Immediately prior to joining Baker McKenzie, he served as Deputy Assistant Secretary for International Tax Affairs at the U.S. Department of the Treasury through the end of the Biden Administration, leading the Office of Tax Policy’s work on international tax affairs — including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2. His practice areas span Tax, Tax Disputes, Tax for M&A and Reorganizations, Tax Policy, and Financial Services Regulatory matters.

 

Shelley Leonard, Esq., Deputy Tax Legislative Counsel | Office of Tax Policy, US Department of the Treasury

Shelley Leonard is Deputy Tax Legislative Counsel in the U.S. Department of the Treasury’s Office of Tax Policy, where she reviews and advises on domestic tax regulations and other guidance. She previously served as Acting Assistant Secretary for Tax Policy and Acting Deputy Assistant Secretary for Tax Policy. Prior to these Treasury roles, she served as a Legislation Counsel at the Joint Committee on Taxation, where she advised on legislative and policy matters relating to tax administration and compliance, individual income tax, health, employment tax, and certain business tax credits. Earlier in her Treasury tenure, she was Deputy Tax Legislative Counsel and an Attorney-Advisor in the Office of Tax Policy, and she has also worked in private practice in the tax group of a law firm, focusing on federal tax controversy, litigation, and counseling. She began her legal career as a trial attorney for the U.S. Department of Justice, Tax Division.

• Education & Credentials

Shelley received her B.A., cum laude, from Dartmouth College and her J.D., cum laude, from Harvard Law School.

• Professional Involvement

Shelley is an active participant in the tax policy community, serving as a speaker at the D.C. Bar Tax Conference — including a panel on recent guidance on clean energy tax credits — and at the D.C. Bar Tax Legislative and Regulatory Update Conference.

• Experience

Shelley currently serves as Deputy Tax Legislative Counsel in the Treasury’s Office of Tax Policy, where she reviews and advises on domestic tax regulations and other guidance, and she has served in the acting capacities of Assistant Secretary for Tax Policy and Deputy Assistant Secretary for Tax Policy. Before her current role, she was a Legislation Counsel at the Joint Committee on Taxation, advising on legislative and policy matters relating to tax administration and compliance, individual income tax, health, employment tax, and certain business tax credits. Earlier, she served as Deputy Tax Legislative Counsel and as an Attorney-Advisor in the Office of Tax Policy, and she practiced as an associate in the tax group of a law firm in the areas of federal tax controversy, litigation, and counseling. She began her legal career as a trial attorney with the U.S. Department of Justice, Tax Division, and earlier served as a law clerk to the Honorable Michael Baylson in the U.S. District Court for the Eastern District of Pennsylvania.

 

Pamela Grewal, Esq., Managing Director | Andersen Tax

Pamela Grewal is a Managing Director in the US National Tax practice at Andersen, based in San Francisco. She draws on over 17 years of government experience to assist clients in navigating federal tax controversy matters. After launching her career at the Department of Justice Tax Division, she transitioned to the IRS Counsel’s National Office in Washington, D.C., where she advised IRS and DOJ personnel on emerging issues in the tax-exempt organizations sector and drafted letter rulings and regulations. Upon relocating to the San Francisco office, her legal expertise expanded significantly: she litigated cases for various divisions — including TEGEDC, LBI, SB/SE, and Strategic Litigation — and advised numerous examination teams on a wide range of issues, including Indian tribal government affairs, employment taxes, research credits, and transfer pricing.

• Education & Credentials

Pamela earned her B.A. in Economics from Pomona College and her J.D. from The University of Michigan Law School.

• Recognition & Leadership

Pamela is, a sought-after speaker on tax controversy matters, having presented at leading national programs including the Practising Law Institute’s Nuts and Bolts of Tax Controversy and its Tax Strategies conference, UCLA’s Tax Controversy Conference, the ABA Tax Section’s Criminal Tax Fraud and Tax Controversy Conference, and the ABA’s Fall Tax Meeting, and she has served as a co-chair of the NYU Tax Controversy Forum.

• Professional Involvement

Pamela is a member of the California Bar Association, the Maryland State Bar Association, the American Bar Association (Tax Section), and the Federal Bar Association, and she is admitted before the United States Tax Court. She is an active panelist and commentator on federal tax controversy developments, including agency deference following the Supreme Court’s Loper Bright decision, the Employee Retention Credit, and other enforcement priorities.

• Experience

Pamela brings more than 17 years of federal government experience to her practice. She began her career as a trial attorney at the Department of Justice Tax Division, then served in the IRS Counsel’s National Office in Washington, D.C., advising IRS and DOJ personnel on emerging tax-exempt organization issues and drafting letter rulings and regulations. After relocating to San Francisco, she litigated cases on behalf of the government for multiple divisions — including TEGEDC, LBI, SB/SE, and Strategic Litigation — and provided technical guidance to examination teams on matters such as Indian tribal government affairs, employment taxes (including worker classification and withholding), research credits, and transfer pricing. Immediately before joining Andersen, she served as a Special Trial Attorney in the IRS’s Strategic Litigation division, where she litigated complex cases of national significance on behalf of the government. She now advises clients on federal tax controversy matters in Andersen’s US National Tax practice.

 

Erin M. Collins, Esq., National Taxpayer Advocate | Internal Revenue Service

Erin M. Collins is the National Taxpayer Advocate, appointed to the role in March 2020 by Secretary Mnuchin. In this position she oversees the Taxpayer Advocate Service (TAS) and serves as the “Voice of the Taxpayer” within the IRS and before Congress. TAS operates as a “safety net” for taxpayers by advocating for the resolution of individual and business taxpayer issues within the IRS, and it also administers the Low Income Taxpayer Clinic federal grant program and the Taxpayer Advocacy Panel. As National Taxpayer Advocate, Erin identifies and works toward systemic changes for all taxpayers while protecting taxpayer rights, and through her Annual Report to Congress she advances administrative and legislative changes intended to protect those rights and improve the quality of taxpayer service and tax administration as an independent voice inside the IRS. She regularly testifies before the Senate Finance Committee, the U.S. House Ways and Means Committee Oversight Subcommittee, and the Senate Appropriations Subcommittee on tax administration and taxpayer rights.

• Education & Credentials

She has over 35 years of experience in tax law and previously spent 15 years in the IRS Office of Chief Counsel and 20 years at KPMG LLP.

• Recognition & Leadership

Erin has received broad recognition across the accounting and tax professions. In 2022, the American Institute of CPAs (AICPA) and CPA Practice Advisor selected her as one of the top 25 Most Powerful Women in the Accounting Profession; Accounting Today recognized her as one of the 100 Most Influential People in Accounting; and Money.com named her a Changemaker among 50 Innovators Shaping Americans’ Finances. In 2023, she received KPMG’s Fifth Annual Network of Women Alumni Legacy Award and the California Lawyers Association’s Joanne M. Garvey Lifetime Achievement Award, and Accounting Today again named her one of the 100 Most Influential People in Accounting. The UCLA Extension Tax Controversy Institute selected her to receive the Bruce I. Hochman Award in recognition of her proficiency in tax law and her leadership, and Accounting Today again recognized her on its top 100 list in 2024.

• Professional Involvement

Erin is frequently cited in national news media and tax publications and appears annually as a guest on C-SPAN’s Washington Journal program. She is co-author of the Practising Law Institute’s IRS Practice and Procedure Deskbook and frequently speaks on IRS practice, procedure, controversy, and litigation matters before professional organizations and on government and tax-industry podcasts. Before joining TAS, she represented several clients pro bono to help resolve issues with the IRS and served as a volunteer and board member of the non-profit Step Up, which helps girls in under-resourced communities become confident, college-bound, and career-focused.

• Experience

Erin has more than 35 years of experience in tax law, spanning 15 years in the IRS Office of Chief Counsel and 20 years at the accounting firm KPMG LLP, where she retired in 2019 as the Tax Managing Director in charge of the firm’s tax controversy practice for the Western region. Throughout her KPMG career she represented thousands of individuals, partnerships, small companies, and corporate taxpayers in federal examinations, IRS appeals, and before the U.S. Tax Court on domestic and international tax issues. Since March 2020, she has served as the National Taxpayer Advocate, leading TAS and delivering the statutory Annual Report and mid-year Objectives Report to Congress.

 

Meghan R. Biss, Esq., Partne | Loeb & Loeb

Meghan R. Biss is a Partner at Loeb & Loeb LLP who counsels tax-exempt and nonprofit organizations at every stage of their lifecycle, advising on tax planning, compliance, and audit matters. As a former senior advisor in the Internal Revenue Service (IRS) Exempt Organizations division, she leverages over 10 years of government experience to guide clients through interactions with the IRS, the U.S. Department of the Treasury, and other government agencies. She represents a diverse array of organizations, including private foundations, national and foreign charities, social welfare organizations, colleges and universities, lobbying and political organizations, and trade associations. Meghan guides clients through applications for tax-exempt status, private letter ruling requests, and other IRS submissions; advises private foundations on excise tax issues; supports the development of compliant programmatic activities; and conducts mock audits and compliance reviews to help organizations strengthen their positions ahead of examinations. She also advises clients in tax controversy matters — including audits, investigations, and litigation involving tax-exempt status and public charity classification — and represents organizations before the U.S. Tax Court.

• Education & Credentials

Meghan earned her J.D., cum laude, from American University Washington College of Law, where she was a member of the Moot Court Honor Society and received the ABA National Appellate Advocacy Competition Award for National Best Brief. She holds a B.S. from Frostburg State University. She is admitted before the U.S. Tax Court and in the District of Columbia and Maryland.

• Recognition & Leadership

Meghan was named “Lawyer of the Year” in Nonprofit/Charities Law for Washington, D.C. by The Best Lawyers in America (2025) and has been recognized as a “Best Lawyer” in Nonprofit/Charities Law by the same publication (2024–2026). She was named in The Legal 500 US for Nonprofit and Tax Exempt Organizations (2025). During her government service, she received the Commissioner’s Award for her work on the Achieving a Better Life Experience (ABLE) Act 529A and Certified Professional Employer Organization (CPEO) Implementation Team (May 2017) and the Distinguished Service Award from Tax Exempt and Government Entities (January 2018). In 2026, she was elected a Fellow of the American College of Tax Counsel.

• Professional Involvement

Meghan serves as Vice Chair of the Exempt Organizations Committee of the American Bar Association Section of Taxation, and was formerly Vice Chair for Legislative Developments within that committee. She is an Associate Member of the Exempt Organizations Technical Resource Panel of the American Institute of Certified Public Accountants (AICPA) and a member of the American Bar Association. A frequent speaker at national industry institutes, seminars, and conferences on legal issues affecting nonprofits and tax-exempt organizations, her recent engagements include the AICPA Not-for-Profit Industry Conference, Georgetown Law’s Conference on Representing & Managing Tax-Exempt Organizations, the TEGE Annual Exempt Organizations Update and Meeting, the DC Bar’s Annual Tax Conference, and Clark Nuber’s Western Philanthropy Conference.

• Experience

Meghan brings more than 10 years of IRS experience to her practice. During her time at the IRS, she served as senior technical advisor to the director of exempt organizations, advising on all matters related to nonprofits and tax-exempt organizations — including overhauling the application process and enhancing the data-driven approach to examinations — and collaborating with the IRS Chief Counsel and the Treasury Department on the development of regulations and guidance on donor-advised funds, supporting organizations, and political campaign intervention activities. She worked closely with the IRS Division Counsel and the U.S. Department of Justice on exempt organization litigation. Prior to that role, she addressed a wide range of public-sector issues including disaster relief, unrelated business income tax (UBIT), excess benefit transactions, charter and private schools, and environmental concerns. As a Presidential Management Fellow, she served as a special attorney in the Civil Appellate Section of the Tax Division at the Department of Justice, handling a variety of appellate tax litigation issues. She joined Loeb & Loeb as a partner in its Nonprofits and Tax-Exempt Organizations practice in 2024.

 

Susanne Sachsman Grooms, Esq., Partner | Cooley

Susanne Sachsman Grooms is a Partner at Cooley LLP, where she leads the firm’s bipartisan congressional investigations practice. A former federal prosecutor and one of the nation’s leaders in congressional investigations, her practice focuses on helping clients navigate high-stakes, complex investigations that potentially involve multiple federal and state agencies, Congress, and regulatory authorities, as well as significant reputational concerns. Her record of leading hundreds of congressional investigations from inside the government gives her a leading edge in assisting clients with congressional investigations, other government and regulatory investigations, internal investigations, and crisis management. She provides counsel and advice in support of and during matters before Congress, having assisted clients in front of investigatory committees and in responding to individual member requests in both the House and Senate, and she has prepared numerous company executives for public testimony in inquiries around the globe.

• Education & Credentials

Susanne earned her J.D. from Harvard Law School and her B.A., cum laude, from Yale University. She is admitted to practice in New York and the District of Columbia.

• Recognition & Leadership

Susanne is ranked by Chambers USA in Band 1 for Government Relations: Congressional Investigations — Nationwide (2023–2025) and was named to Lawdragon’s 500 Leading Litigators in America (2026). She is recognized in The Legal 500 US for Corporate Investigations and White-Collar Criminal Defense (2025), as a Future Star by Benchmark Litigation, among the Most Influential People in Washington by Washingtonian magazine, and among Lawdragon’s 500 Leading Plaintiff Employment & Civil Rights Lawyers. During her government service she received the Tax Division Outstanding Attorney Award (2005) and the Tax Division Special Act or Service Award (2006) from the U.S. Department of Justice.

• Professional Involvement

Susanne teaches Congressional Investigations at the Georgetown University Law Center and is a frequent speaker on matters related to congressional oversight and investigations. She has been an invited speaker at events organized by the American Bar Association, the New York City Bar Association, the University of Pittsburgh Institute of Politics, and the Dick Thornburgh Forum for Law and Public Policy, and she serves on Law360’s Massachusetts editorial advisory board (2025).

• Experience

Susanne began her career as a trial attorney in the Tax Division of the U.S. Department of Justice, where she was a member of the Attorney General’s Honors Program. From 2008 to 2010, she served in a number of roles at the Internal Revenue Service, including as attorney adviser to the deputy commissioner for services and enforcement and as senior counsel to the chief of criminal investigation. In 2010, she was detailed to the White House, where she served as deputy associate counsel in the Office of Presidential Personnel, vetting presidential appointments and nominations and advising on tax compliance and other legal matters. She joined the U.S. House Committee on Oversight and Government Reform — the principal investigative committee of the U.S. House of Representatives — as counsel under Chairman Henry A. Waxman, and advanced into senior leadership, supervising and conducting hundreds of congressional hearings and investigations and leading the committee’s investigative staff from 2011 to 2021. As deputy staff director and chief counsel for then-Chairwoman Carolyn Maloney and her predecessor Chairman Elijah E. Cummings, she oversaw a team of more than 70 attorneys, investigators, and communications and support staff on hundreds of high-profile investigations, and she served on the investigatory and Senate trial teams for both impeachments of Donald J. Trump. Since February 2024, she has led Cooley’s congressional investigations practice, where her representations include advising Fortune 500 companies, financial institutions, universities, media organizations, and senior executives in connection with investigations and public testimony before congressional committees in the U.S. and abroad.

 

Casey A. Lothamer, Esq., Senior Counsel | Loeb & Loeb

Casey A. Lothamer is Senior Counsel at Loeb & Loeb LLP in Washington, DC, where he advises nonprofits and tax-exempt organizations across the full spectrum of federal tax and regulatory matters, ranging from organizational structuring and tax-exemption issues to governance, compliance, IRS controversy and operational matters. Drawing on nearly 20 years of experience within the IRS Tax Exempt & Government Entities Division Counsel (TEGEDC), he guides clients through IRS examinations, determinations, compliance matters, audits, investigations and tax controversy proceedings. Casey advises public charities, private foundations, social welfare organizations and international nonprofits with U.S. affiliates on governance, operational structuring and compliance with federal tax requirements applicable to exempt organizations. He assists with tax-exempt status applications, private letter ruling requests and other agency submissions, as well as excise tax matters affecting private foundations and the implementation of compliant charitable programs. He also conducts mock audits and compliance assessments to help organizations identify potential issues and strengthen their preparedness ahead of examinations, represents clients in tax controversy and enforcement matters — including matters before the U.S. Tax Court — and counsels clients on regulatory developments affecting exempt organizations while engaging with government officials on Treasury regulations and IRS guidance.

• Education & Credentials

Casey earned an LL.M. in Taxation from Georgetown University Law Center and his J.D. from the University of Pittsburgh School of Law, where he served as Founder and Executive Editor of the Pittsburgh Tax Review. He holds a B.S. from the University of Central Florida. He is admitted to practice before the U.S. Supreme Court and the U.S. Tax Court and is admitted only in Maryland.

• Recognition & Leadership

Casey served as a Former Adjunct Professor at the University of Baltimore School of Law from 2024 to 2025.

• Experience

Before joining Loeb, Casey served for nearly two decades across a progression of senior roles within the TEGEDC of the Office of Chief Counsel at the IRS, including as senior level counsel and area counsel, where he was instrumental in shaping and advancing the IRS’ legal positions on complex exempt organization matters. While at the TEGEDC, he led and supervised significant, high-stakes litigation at both the trial and appellate levels and served as the primary technical authority for exempt organization issues within his branch. He played a central role in reviewing, approving and issuing guidance on the federal tax treatment of sophisticated transactions involving tax-exempt entities, including regulations with nationwide impact, and oversaw technical advice provided to both the public and the IRS. He also reviewed defense submissions to the U.S. Department of Justice in declaratory judgment actions brought by tax-exempt organizations.

 

Michael Waalkes, Esq., Associate | Kostelanetz

Mike Waalkes is an associate with Kostelanetz LLP, based in the firm’s Washington, D.C. office. He focuses his practice on civil and criminal tax controversy matters, including audits, promoter investigations, voluntary disclosures, U.S. Tax Court litigation, and criminal tax investigations. Prior to joining the firm, Mike served for two years as a judicial law clerk for Judge Joseph W. Nega of the U.S. Tax Court. In addition to his practice, Mike is an adjunct professor at Villanova University’s Charles Widger School of Law, where he co-teaches a course on federal tax practice and procedure in the school’s graduate tax program. He also maintains an active pro bono practice representing low-income taxpayers before the Internal Revenue Service and the U.S. Tax Court.

• Education & Credentials

Mike received his J.D. and LL.M. in Taxation from Boston University School of Law in 2021. He holds a master’s degree in international affairs from American University, earned in 2016, and graduated magna cum laude from the University of Pittsburgh in 2014 with degrees in political science and film studies. Mike is admitted to practice in the District of Columbia, as well as before the U.S. Tax Court, the U.S. District Court for the District of Columbia, the U.S. Court of Appeals for the Third Circuit, the U.S. Court of Appeals for the Fourth Circuit, and the U.S. Court of Federal Claims.

• Recognition & Leadership

During law school, Mike served as an editor on the Review of Banking and Financial Law journal.

• Professional Involvement

Mike is an adjunct professor at Villanova University’s Charles Widger School of Law, where he co-teaches a course on federal tax practice and procedure in the school’s graduate tax program. He also maintains an active pro bono practice representing low-income taxpayers before the Internal Revenue Service and the U.S. Tax Court.

• Experience

Mike focuses his practice on civil and criminal tax controversy matters, including audits, promoter investigations, voluntary disclosures, U.S. Tax Court litigation, and criminal tax investigations. Before joining Kostelanetz, he served for two years as a judicial law clerk for Judge Joseph W. Nega of the U.S. Tax Court. During law school, he worked as an intern for the low-income taxpayer clinic at Harvard Law School’s Legal Services Center, as a research assistant for Professor T. Keith Fogg of Harvard Law School, and as a summer associate and law clerk with Kostelanetz. Prior to law school, Mike worked as a paralegal at a tax controversy firm in the D.C. metro area.

 

Philipp Behrendt, Esq., Principal | Hochman Salkin Toscher Perez, PC

Philipp Behrendt is licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Prior to joining the firm, Mr. Behrendt worked for more than five years for a leading German tax firm, where he focused on representing wealthy individuals and companies in global tax settings, cross-border investigations and audit matters, as well as tax compliance issues arising from internationally functioning matrix structures.

• Education & Credentials

Mr. Behrendt is an LL.M. graduate of the University of Southern California (USC) Gould School of Law and an LL.M. graduate of the University of Osnabrueck (Germany), where he completed the LL.M. Program in White Collar Crime, and he holds a law degree (German law diploma) from the University of Greifswald (Germany). He is admitted to the State Bar of California and the German Bar.

• Recognition & Leadership

Mr. Behrendt serves as a member and Vice-Chair of the Young Lawyer Leaders for Global Anti-Corruption Committee of the American Bar Association, a position he has held since July 2019.

• Professional Involvement

Mr. Behrendt is a member of the American Bar Association, including its White-Collar Crime Division, since July 2019, and serves as Vice-Chair of the Young Lawyer Leaders for Global Anti-Corruption Committee. His publications and speaking activities include “An Update on Cryptocurrency Enforcement and Voluntary Disclosures” at the UCLA 39th Annual Tax Controversy Institute; “Ethical Considerations for Tax Attorneys in Changing Work Environment” at the ABA Virtual 2023 Fall Tax Meeting; “Cryptocurrency Tax Compliance” for CalCPA; “New Developments in Cryptocurrency Reporting and Enforcement” for CPA Academy; “The Ins and Outs of Tax Audits” and “Tax Impacts of the Inflation Reduction Act” for the Beverly Hills Bar Association; “Tax Evasion as a Predicate Offense for Money Laundering under German and US Law” (ZIS 4/2020, 196); “Taxation of Crypto Currency – the digital foreign currency account” (DStA 2018, 342, co-authored with Sven Janken, in German); “GateKeepers: AML Compliance for Legal and Tax Advisors” (PStR 1028, 140, co-authored with Johann Meyer, in German); “The Act of Combating Tax Avoidance – New big data volumes for the tax authorities” (WiJ 2018, co-authored with Johann Meyer, in German); and participation on an American Bar Association Panel on the Impact of the Panama Papers.

• Experience

Mr. Behrendt advises clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures, and focuses on the technical aspects of advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Prior to joining the firm, he worked for more than five years for a leading German tax firm, where he focused on representing wealthy individuals and companies in global tax settings, cross-border investigations and audit matters, and tax compliance issues arising from internationally functioning matrix structures. During that time, Mr. Behrendt obtained experience handling complex voluntary disclosure issues for U.S. and other international companies, representing clients in German tax and criminal courts as well as in international money laundering investigations stemming from tax avoidance structures of the client’s business partners and customers. He has worked with client tax teams throughout Europe, the U.S., and the Arabic region.

 

Sean P. McElroy, Esq., Partner | Fenwick & West

Sean P. McElroy is a Partner in the Tax practice at Fenwick & West LLP, based in the firm’s Seattle office. He advises clients, including early-stage startups, unicorns, and Fortune 100 multinationals, on a wide array of domestic and international tax planning and tax controversy matters. Sean has particular expertise advising clients on tax matters related to blockchain and cryptocurrency ecosystems, having advised numerous clients on tax issues relating to token generation events, private token sales, NFTs, decentralized autonomous organizations (DAOs), and centralized and decentralized cryptocurrency structures. His clients in this space include protocol development teams, founders, investment platforms, cryptocurrency exchanges, and individual investors. Sean is a lecturer in law at Stanford Law School, where he taught courses in Corporate Income Tax and Blockchain Tax.

• Education & Credentials

Sean earned his J.D. from Stanford Law School and holds an A.B., magna cum laude, in History and Philosophy. He is admitted to practice in California and Washington State.

• Recognition & Leadership

Sean’s 2018 article in the Yale Journal on Regulation Bulletin was quoted by the dissenting opinion in the U.S. Supreme Court’s 2024 ruling in Moore v. United States, a landmark case on the constitutionality of the Mandatory Repatriation Tax provisions of the Tax Cuts and Jobs Act of 2017. During law school, Sean was a member of the Stanford Law Review and was a student Bradley Fellow at the Stanford Constitutional Law Center.

• Professional Involvement

Sean is a lecturer in law at Stanford Law School, where he taught courses in Corporate Income Tax and Blockchain Tax. He has also spoken at events hosted by IFA and the American Bar Association on the taxation of cryptocurrency.

• Experience

Sean advises clients, including early-stage startups, unicorns, and Fortune 100 multinationals, on domestic and international tax planning and tax controversy matters. He has particular expertise in tax matters related to blockchain and cryptocurrency ecosystems, advising clients on token generation events, private token sales, NFTs, decentralized autonomous organizations (DAOs), and centralized and decentralized cryptocurrency structures, with clients including protocol development teams, founders, investment platforms, cryptocurrency exchanges, and individual investors. He has experience representing clients in tax controversies, including large multinational companies in advance pricing agreements, tax arbitrations, administrative proceedings against the IRS, in U.S. District Court, and in the U.S. Tax Court, and has represented taxpayers in controversies relating to the taxation of cryptocurrency. Sean has advised several Fortune 100 companies on international and domestic tax planning matters, including transfer pricing, foreign tax credit utilization, GILTI, Subpart F, and international M&A and restructurings. He clerked for the Honorable Dale S. Fischer on the U.S. District Court for the Central District of California.

 

Amber R. Salotto, Esq., Managing Director | RSM US

Amber Salotto is a Managing Director with RSM US LLP’s Washington National Tax compensation and benefits practice, where she specializes in executive compensation, equity compensation, qualified and nonqualified plans, and other related topics. Previously, she spent more than two years at the Department of the Treasury as an attorney-advisor to Benefits Tax Counsel within the Office of Tax Policy, where she was responsible for regulatory and legislative matters related to the taxation of compensation and benefits, including cryptocurrency, tax law changes under the TCJA, the SECURE Act, and various economic stimulus and COVID-19 relief measures. Earlier, she spent more than 10 years at Deloitte, most recently with their compensation and benefits practice in Washington National Tax, where she served as a national practice resource on cryptocurrency as compensation. She also previously served with the US National Tax Practice at Andersen.

• Education & Credentials

Amber earned a B.A. from New York University and a J.D. from Drexel University School of Law (Thomas R. Kline School of Law). She is admitted to the Bar in both the District of Columbia and Pennsylvania.

• Professional Involvement

Amber is a member of RSM’s Washington National Tax practice and is an author and speaker on compensation and benefits tax topics. She co-authored commentary published by Bloomberg Tax addressing information reporting and income tax changes affecting cash tips, overtime, and employer-provided meals. She has spoken at the D.C. Bar Tax Conference, including sessions addressing employee retention tax credits, and at the Northern Virginia Estate Planning Council on equity compensation and related tax topics.

• Experience

Amber’s practice focuses on executive compensation, equity compensation, qualified and nonqualified plans, fringe benefits, employment tax matters, and cryptocurrency as compensation. At the Department of the Treasury, she served as an attorney-advisor to Benefits Tax Counsel within the Office of Tax Policy, responsible for regulatory and legislative matters related to the taxation of compensation and benefits. During her tenure at Deloitte’s Washington National Tax compensation and benefits practice, she consulted on a broad range of compensation and benefits issues and served as a national practice resource on cryptocurrency as compensation. She also previously held a Managing Director role with Andersen’s US National Tax Practice.

 

Debra Silverman Herman, Esq., Partner | Hodgson Russ

Debra Silverman Herman is a partner in the State & Local Tax Practice at Hodgson Russ LLP, resident in the firm’s New York City and Hackensack, New Jersey offices. She is widely recognized for her experience in state and local taxation. Debra works with a variety of clients to address the state and local tax impact of their multistate activities from both a planning and an audit and controversy viewpoint and on complex transactions, with a focus on New York State tax matters. She counsels clients with respect to corporate income and franchise taxes, bank taxes, utility taxes, unincorporated business taxes, sales and use taxes, gross receipts taxes, excise taxes on real property transfers, rent and occupancy taxes, and withholding taxes. Debra also has extensive experience working with high-net-worth clients on residence and other personal income tax matters and successfully representing clients in all phases of tax disputes, including audits and litigation at the federal, state, and local levels, as well as criminal tax investigations.

• Education & Credentials

Debra earned her B.A. from the University of Wisconsin, Madison; her J.D. from American University Washington College of Law; and her LL.M. in Taxation from New York University School of Law. She is admitted to practice in New York, New Jersey, and the District of Columbia.

• Recognition & Leadership

Debra has been listed in Super Lawyers New York Metro Rising Stars (2013 and 2014) and was featured in Careers in Tax Law, published by the American Bar Association. She is a former editor in chief of The Tax Lawyer—The State and Local Tax Edition and the State and Local Tax Lawyer—Symposium Edition, both published by the American Bar Association Section of Taxation, and a former associate executive editor of the American University International Law Review. Debra is a fellow of the American Bar Foundation and a fellow of the American College of Tax Counsel. She was also featured in Crain’s New York Business “2023 Notable Leaders in Accounting, Tax & Audit” list.

• Professional Involvement

Debra is the immediate past chair of the American Bar Association Tax Section’s Committee on State and Local Taxes and has also served as the chair of the State and Local Tax Committee of the New York City Bar Association, where she is a current member. She is also a member of the New York State Bar Association Tax Section’s Committees on New York State Tax Matters and New York City Tax Matters. A nationally recognized author on state tax topics, Debra co-authored the BNA Portfolio “New York Sales and Use Taxes” and a bi-monthly article on New York State and New York City taxation in the New York Law Journal, and she writes a quarterly column in the Journal of Taxation on state and local tax matters before the U.S. Supreme Court. She is a frequent speaker on state and local tax issues and has appeared before such groups as Tax Executives Institute, the Institute for Professionals in Taxation, the American Bar Association, the New York State Bar Association, the New York City Bar Association, and the New York State and New Jersey Societies of Certified Public Accountants.

• Experience

Debra has over 20 years of experience representing clients in state tax audits and New York State and New York City tax litigation, obtaining federal and state rulings and advisory opinions, providing tax opinion letters, and assisting with voluntary disclosures and collection matters. Her clients have included domestic and global financial service companies, law firms, real estate investment trusts and cooperatives, manufacturers, retailers, energy companies, airlines, entertainers, high-net-worth individuals, and tax-exempt organizations. She has worked with many clients on issues of nexus, combination, sourcing of income among states, allocation of tax credits and incentives, aggregation and controlling interest real property transfers, and taxability of activities and transactions for sales and use tax purposes. Debra also has in-depth experience in the area of state tax residency and assists clients from the planning stage through the audit and appeals process.

 

Catherine Chiou, Esq., Managing Director | Andersen Tax

Catherine Chiou is a Managing Director in Andersen’s State and Local Tax (SALT) practice in New York, NY. She has over 13 years of experience providing tax services to corporate and high-net-worth clients with regard to state and local tax compliance and consulting involving income and franchise taxes, sales and use taxes, gross receipts taxes, and unclaimed property. Catherine has advised a multitude of clients on state and local tax matters associated with tax refund and planning opportunities, tax controversies, voluntary disclosures, state residency planning, nexus reviews, and credits and incentives projects. She specializes in state and local tax consulting, advisory, audit defense and controversy, planning, and compliance.

• Education & Credentials

Catherine earned a BA from New York University, a JD from Fordham University School of Law, and an LLM from the University of San Francisco School of Law. She was admitted to the New York Bar in 2011 (Second Judicial Department) and is a registered attorney with the New York State Unified Court System’s Office of Court Administration.

• Recognition & Leadership

Catherine was elevated to Managing Director at Andersen in the firm’s 2024 promotions class, recognized as a member of the SALT practice in New York specializing in state and local tax consulting, advisory, audit defense and controversy, planning, and compliance.

• Professional Involvement

Catherine is a member of the New York City Bar Association’s State and Local Taxation Committee. She has served as a presenter on Andersen’s behalf for the Tax Executives Institute (TEI) New York Chapter, including a multi-part 2024 webcast series, “Partnership Perspectives: Formation, Operations and Dissolution.”

• Experience

Catherine has over 13 years of experience providing tax services to corporate and high-net-worth clients in state and local tax compliance and consulting, involving income and franchise taxes, sales and use taxes, gross receipts taxes, and unclaimed property. She has advised a multitude of clients on state and local tax matters associated with tax refund and planning opportunities, tax controversies, voluntary disclosures, state residency planning, nexus reviews, and credits and incentives projects. Prior to joining the state and local taxation practice, Catherine worked in Andersen’s Private Client Services practice, advising on tax and financial matters affecting high-net-worth individuals and their related entities.

 

Richard L. Jones, Esq., Partner | Sullivan & Worcester

Richard L. Jones is the leader of Sullivan & Worcester’s Tax Group, based in the firm’s Boston office. He concentrates on state and local tax (SALT) litigation and transactional planning involving corporate, personal income, and sales/use tax matters. He has more than two decades of experience before the Massachusetts Appellate Tax Board, the Supreme Judicial Court, various state Departments of Revenue, and the Internal Revenue Service on a range of issues, including corporate nexus, domicile, apportionment, step transaction, and unitary reporting. Rich has served clients across sectors including technology, financial services, retail, media, manufacturing, telecommunications, e-commerce, software, and construction.

• Recognition & Leadership

Rich has developed a strong record representing clients in SALT controversies. He argued and prevailed before the Massachusetts Supreme Judicial Court in the precedent-setting case Oracle v. Commissioner of Revenue, which affirmed the right of businesses to apportion sales tax on software used in multiple states; the Oracle decision was named a top SALT case of 2021 by Law360 and a Top Indirect Tax Dispute Worldwide for Q2 2021 by International Tax Review. In 2022, he was selected as a finalist for Litigator of the Year by The American Lawyer. In 2021, the editors of Law360 selected Rich as Tax MVP and published a profile of his career, and he was named a “Lawyer of the Year” by Massachusetts Lawyers Weekly. He has been recognized by International Tax Review’s Tax Controversy Leaders’ Guide for several years and was shortlisted by ITR Americas for North America Indirect Tax Practice Leader of the Year in August 2020 and August 2022. He has also been recognized and ranked by The Legal 500 U.S., Chambers USA, and Best Lawyers in America, named to Boston Magazine’s 2021 Top Lawyers (Tax), and listed in Massachusetts Super Lawyers and, earlier, as a “Rising Star” in Massachusetts Super Lawyers. He received the Pro Bono Attorney Award from Boston University School of Law’s Public Interest Project in 2013.

• Professional Involvement

Rich formerly taught State and Local Taxation as an adjunct professor at Northeastern University’s D’Amore-McKim Graduate School, MS in Taxation Program. He is active with the American Bar Association’s Tax Section, where he co-chairs the SALT Subcommittee on Income & Net Worth, and he previously served as co-chair of the Boston Bar Association’s Tax Section and its State Tax Committee. Rich is co-author of “Taxation,” Vols. 4–4C of Thomson Reuters’ Massachusetts Practice Series, and frequently writes and speaks at seminars on SALT topics. He has been quoted on tax matters in numerous publications, including Tax Notes, Bloomberg, Law360, The Boston Globe, and the Boston Herald.

• Experience

Rich concentrates on SALT litigation and transactional planning involving corporate, personal income, and sales/use tax matters, with more than two decades of experience before the Massachusetts Appellate Tax Board, the Supreme Judicial Court, various state Departments of Revenue, and the Internal Revenue Service on issues including corporate nexus, domicile, apportionment, step transaction, and unitary reporting. He has served clients across sectors including technology, financial services, retail, media, manufacturing, telecommunications, e-commerce, software, and construction, and has built a strong record in SALT controversies, including landmark Massachusetts tax cases such as his win before the Supreme Judicial Court in Oracle v. Commissioner of Revenue.

 

Deanne Morton, Esq., Managing Director | Andersen Tax

Deanne Morton is a Managing Director in the Andersen US National Tax practice, based in San Francisco, CA, where she works within the firm’s Tax Controversy practice. A former practicing attorney with a master’s degree in taxation, Deanne draws on her over 20 years of experience to serve Andersen clients in navigating Federal Tax Controversy matters. She represents clients through all stages of IRS audits and appeals, including navigating and responding to information document requests, negotiating proposed adjustments and settlements, and working with outside counsel to support and defend tax positions. Deanne also resolves all IRS practice and procedure matters, including penalty abatement, disaster tax relief, voluntary disclosure, excise tax, employment tax, foreign and domestic information withholding and reporting, employee identification numbers, entity classification, R&D credit, transfer pricing, residency certifications, collection due process, and refund claims. In addition, she helps analyze tax policy and legislative developments, assists with business and individual tax planning, and plays an integral role in the firm’s thought leadership and knowledge management efforts.

• Education & Credentials

Deanne earned a BA in Global Affairs from the University of North Carolina at Chapel Hill, a JD from the University of North Carolina School of Law, and an LLM in Taxation from Golden Gate University School of Law. She is admitted to practice before the U.S. Tax Court and is a member of the California and Georgia State Bar Associations.

• Recognition & Leadership

Deanne was appointed to the AICPA’s Tax Practice Responsibilities Committee, including for the 2024–2025 service year. Her insights on Federal Tax Controversy have been featured in the American Bar Association’s ABA Tax Times, where she authored the “At Court” column “Agency Authority, Judicial Oversight, and the Fate of Chevron Deference,” addressing the level of deference courts should afford to agency rulemaking and two related cases pending before the U.S. Supreme Court.

• Professional Involvement

Deanne is affiliated with the American Bar Association (ABA), the American Institute of Certified Public Accountants (AICPA), the California State Bar Association, the Georgia State Bar Association, and the U.S. Tax Court Bar. She serves on the ABA Tax Section’s Administrative Practice and Standards of Practice Committees and was appointed to the AICPA’s Tax Practice Responsibilities Committee. She is also an author and commentator on federal tax controversy and tax policy topics.

• Experience

Deanne draws on over 20 years of experience serving clients in Federal Tax Controversy matters. She represents clients through all stages of IRS audits and appeals—navigating and responding to information document requests, negotiating proposed adjustments and settlements, and working with outside counsel to support and defend tax positions—and resolves IRS practice and procedure matters including penalty abatement, disaster tax relief, voluntary disclosure, excise tax, employment tax, foreign and domestic information withholding and reporting, employee identification numbers, entity classification, R&D credit, transfer pricing, residency certifications, collection due process, and refund claims. Before joining Andersen, Deanne was a Managing Editor with LexisNexis, where she developed a leading research platform for tax practitioners and served as editor-in-chief of a premier federal tax journal. She also worked as an attorney with the multinational law firms of King & Spalding LLP and Bryan Cave Leighton Paisner LLP.

 

Stephen Josey, Esq., Counsel | Vinson & Elkins

Stephen Josey is Counsel in the Tax practice at Vinson & Elkins LLP, based in the firm’s New York office. He is an experienced tax controversy attorney who represents taxpayers in civil and criminal matters involving the Internal Revenue Service, the New York State Department of Taxation and Finance, and the United States Department of Justice. Stephen has extensive experience representing taxpayers during audits and administrative investigations and has litigated a wide range of tax disputes, including Tax Court matters, tax refund suits in federal trial courts, summons enforcement matters, collection actions, injunction suits, and bankruptcy disputes involving tax claim priority and dischargeability. He also has experience litigating tariff-related disputes in the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit. As he describes his approach, he regularly draws upon the skills and knowledge gained from government experience to help clients resolve their tax disputes efficiently and fairly.

• Education & Credentials

Stephen received his J.D. from Vanderbilt University Law School in 2012, where he served as Managing Editor of the Vanderbilt Journal of Entertainment and Technology Law. He earned his B.A. in Economics and Organizational Studies with High Distinction from the University of Michigan in 2009. He is admitted to practice in New York, the District of Columbia, and Tennessee.

• Recognition & Leadership

Stephen is recognized in Tax: Private Client by Chambers High Net Worth USA 2025 (USA Nationwide), where a client noted his encyclopedic knowledge of case facts and his ability to keep sight of the broader issues and strategy. He has been named to The Best Lawyers in America “Ones to Watch” (New York) for Litigation and Controversy – Tax (2022–2025) and Commercial Litigation (2021–2025). While serving at the U.S. Department of Justice, he received the Tax Division’s Outstanding Attorney Award in 2016.

• Professional Involvement

Stephen is a member of the American Bar Association Section of Taxation and is a former Co-Chair of the New York City Bar Association’s Personal Income Taxation Committee. He is an active author and speaker on tax controversy and procedure topics; his publications and presentations include “You Suspect Your Client Committed Tax Fraud: Now What?” (2026, with Brie Barry), “Criminal Tax Investigations and Procedures: What Practitioners Need to Know” (New York County Lawyers Association, 2023, co-speaker), “Diversity in the Tax Bar – Reflections on Lessons Learned and the Path Forward” (Tax Notes, 2023, co-author), “An Inconvenient Truth About Remote Work – Connecticut’s Income-Sourcing Statute Needs Fixing” (CPA Journal, 2023), “Tips on Qualified Small Business Stock Exclusions” (Law360 Tax Authority, 2022), “Accounting for Sales with Contingent Obligations: Methods and Considerations” (CPA Journal, 2020), “This is Privileged, Right? Attorney-Client Communications in the Tax Return Preparation Context” (Journal of Tax Practice and Procedure, 2019, co-author), “Give Me Back My Money: The Life of a Refund Suit” (IRS Representation Conference, 2019, co-panelist), and “To Amend or not to Amend: Correcting Non-compliance on Past Returns” (Journal of Tax Practice and Procedure, 2019, co-author). He spoke at the ABA 2026 May Tax Meeting and on the American College of Tax Counsel (ACTC) Tax Law panel at New York Law School.

• Experience

Prior to joining private practice, Stephen held positions as a trial attorney with both the Tax Division and the Civil Division of the United States Department of Justice, where he was hired through the Attorney General’s Honors Program; he served in the Tax Division from 2013 to 2016 and in the Civil Division’s International Trade Field Office from 2016 to 2018. Immediately after law school, he served as a law clerk for the Honorable J. Daniel Breen of the U.S. District Court for the Western District of Tennessee (2012–2013). His representative matters include representing an individual under criminal investigation by the DOJ Tax Division in a multi-year privilege dispute that culminated in the U.S. Supreme Court granting certiorari in In re Grand Jury (No. 21-1397); defending a client in a tax-shelter promoter injunction action brought by the DOJ under IRC §§ 7402 and 7408 involving “monetized installment sales”; prosecuting a civil action for actual and punitive damages under IRC § 7431 based on the IRS’s unauthorized disclosure of tax return information; representing a client before the Ninth Circuit in an appeal of a Tax Court collateral order denying a motion to seal, raising novel questions on burden of proof under IRC § 6103; authoring two amicus briefs before the Fifth Circuit on the timeliness of supervisory penalty approval under IRC § 6751(b); authoring an amicus brief for the American College of Tax Counsel before the Eleventh Circuit on the substantial variance doctrine in federal tax refund suits; authoring a Tax Court amicus brief on the economic substance doctrine under IRC § 7701(o); obtaining a favorable settlement for a finance executive in a Court of Federal Claims refund action involving foreign tax credits; obtaining a settlement for an estate executor in an S.D.N.Y. suit by the DOJ; managing, as a government attorney, a Federal Circuit appeal on tariff classification under the HTSUS; providing pre-litigation analysis for a large corporation on a potential multi-billion-dollar excise tax refund claim; advising investors on contingent earnouts and qualified opportunity zone fund investments; representing an executive under IRS audit on qualified small business stock exclusion eligibility; and representing high-net-worth individuals and public figures in sensitive tax collection and penalty matters.

 

Gray Proctor, Esq., Counsel | Kostelanetz

Gray Proctor is Counsel with Kostelanetz LLP, based in the firm’s Atlanta, GA office. He is a board-certified appellate specialist and one of fewer than one percent of active Florida Bar members to hold that designation. Gray focuses his practice on federal appellate litigation, with particular depth in tax controversy appeals and APA-based challenges to federal agency action. He brings a combination that is genuinely difficult to find: the procedural command of a dedicated appellate advocate with three federal clerkships, and the substantive fluency of a practitioner embedded in high-stakes tax litigation every day. His appellate practice spans the full arc of federal tax controversies — from preserving constitutional and statutory challenges in the U.S. Tax Court, to coordinating appellate strategy as cases move to the circuit courts, to briefing and oral advocacy in the circuits and the Supreme Court. He also serves as appellate co-counsel to trial firms handling matters outside tax, particularly cases turning on federal agency action and APA procedure. Beyond tax, Gray maintains an active criminal appellate practice; he accepts CJA appointments in the Sixth and Eleventh Circuits, has represented clients in death row clemency proceedings, and earlier in his career contributed to the successful reversal of a high-profile Tennessee murder conviction. He also accepts clients on appeal of civil matters outside of tax, including commercial litigation and insurance coverage.

• Education & Credentials

Gray earned a B.S. from The University of Texas at Dallas (1998), an M.A. from the University of New England (2004), and his J.D. from Vanderbilt University (2007), where he was named to the Dean’s List and received the Book Award in Criminal Procedure. He has been board certified as a Specialist in Appellate Practice by The Florida Bar since 2021. He is admitted in the State of Florida; the State of Georgia; the U.S. District Courts for the Northern, Middle, and Southern Districts of Florida and the Southern District of Georgia; the U.S. Courts of Appeals for the First, Second, Third, Fourth, Fifth, Sixth, and Eleventh Circuits; the United States Tax Court; and the United States Supreme Court.

• Recognition & Leadership

Gray is a Board Certified Specialist in Appellate Practice with The Florida Bar (since 2021, a designation held by fewer than 1% of active Florida Bar members), is AV Preeminent rated by Martindale-Hubbell, and has been recognized as an elite appellate practitioner in Florida Trend magazine’s Florida Legal Elite for Appellate Practice. His published work on SEC v. Jarkesy and its implications for tax penalty procedure has been cited by courts and practitioners as a leading treatment of the administrative law developments reshaping federal regulatory enforcement. His publications include “Jarkesy, Originalism, and the Future of Tax Penalties” (April 2026) and “Can Tax Promoter Penalties be ‘Excessive Fines’ Under the Eighth Amendment?” (October 2025).

• Professional Involvement

Gray served as a federal law clerk in three courts — the U.S. District Court for the Southern District of Texas, the U.S. District Court for the Eastern District of Virginia, and the U.S. Court of Appeals for the Fourth Circuit — before building his appellate practice. He is an author on appellate and tax-penalty topics and participates in firm thought leadership, including a Columbia Law School Moot Court Program engagement. He accepts court-appointed counsel work under the Criminal Justice Act in the Sixth and Eleventh Circuits.

• Experience

Gray’s appellate practice spans federal tax controversies and APA-based challenges to federal agency action. His representative matters include serving as appellate counsel coordinating Jarkesy Seventh Amendment and Article III challenges across multiple Tax Court cases, including representation of the Center for Taxpayer Rights as amicus curiae before the U.S. Tax Court, the Eleventh Circuit, and the U.S. Supreme Court; serving as amicus counsel for the Center for Taxpayer Rights before the U.S. Tax Court in Silver Moss Properties, LLC v. Commissioner, briefing whether the Seventh Amendment right to a jury trial extends to fraud and accuracy penalties under Jarkesy; providing additional amicus briefing in the Eleventh Circuit and the Supreme Court in Hirsch v. United States on the Jarkesy issue; providing briefing support in a consolidated 13-case trial involving conservation easement donation partnerships facing substantial federal tax and penalty liability, including APA arbitrary-and-capricious review and valuation disputes; developing and briefing issues opposing retroactive application of IRS Notice 2017-10 under APA arbitrary-and-capricious review; serving as court-appointed counsel under the Criminal Justice Act in the Sixth and Eleventh Circuits representing indigent defendants in direct criminal appeals; serving as counsel in state and federal post-conviction proceedings, including habeas corpus petitions under 28 U.S.C. §§ 2254 and 2255; and serving as appellate and trial support counsel in a wide variety of state and federal disputes, including commercial litigation, family law, and insurance coverage.

 

John Colvin, Esq., Partner | Colvin + Hallett

John Colvin is an attorney with Colvin + Hallett, a tax law firm in Seattle, Washington. He draws from almost three decades of practice and experience in tax law to develop legal theories and strategies in defense of his clients, and he keeps a close eye on developments in the tax law, enabling him to provide clients with awareness of current developments and their implications. John is a very active and respected member of the American Bar Association Tax Section, having served as Chair of the Committee covering tax controversy matters, and he is often sought out to speak at a national level on various tax law issues. He also teaches Tax Crimes: Investigations, Prosecutions, and Penalties at the University of Washington School of Law. Outside of his practice, John is a wine and food connoisseur always on the lookout for Seattle’s next great restaurant, enjoys swimming, and is an avid reader of non-tax materials.

• Education & Credentials

John earned his J.D. from the University of Washington School of Law in 1991. He held a Fellowship at Columbia University in 17th and 18th Century Chinese History from 1986 to 1988, and he received his B.A. in Anthropology from Reed College in 1985, where he was elected Phi Beta Kappa. He is admitted to the bar in Washington.

• Recognition & Leadership

John is a Fellow of the American College of Tax Counsel and a Fellow of the American Bar Foundation. He has been listed in The Best Lawyers in America from 2013 to 2023 for Criminal Defense: White-Collar and for Litigation and Controversy – Tax, and has been selected to Super Lawyers (Washington Law & Politics) from 2013 to 2023. He has served as an ABA Delegate to the National Conference of Attorneys and CPAs from 2018 to the present.

• Professional Involvement

John is a very active member of the ABA Tax Section. His professional activities include serving on the ABA Tax Section Committee on Government Submissions (2017–present), where he currently oversees Tax Section comments on government regulatory efforts in procedural areas; the ABA Tax Section Civil and Criminal Tax Penalties Committee, as Vice-Chair (2011–2015) and Chair (2015–2017); the ABA Tax Council as a Member (2021–present); the Seattle Tax Group, as Chair (2014) and Member (2010–present); and the ABA Tax Section Subcommittee for Legislative and Administrative Developments, as Chair (2004–2012). He served as an Adjunct Lecturer at the UW School of Law (2016, 2017, 2018) and teaches Tax Crimes: Investigations, Prosecutions, and Penalties there. He has been intimately involved in drafting comments to proposed regulations on behalf of the ABA Tax Section, including as primary drafter of comments to preparer penalty regulations (§ 6694) and assisting in drafting comments to list maintenance regulations (§ 6708) and to penalty regulations for failure to report IRS “reportable transactions” to the SEC (§ 6707A(e)). John is a frequent national speaker and prolific author; his presentations and publications include “Audits of Exempt Orgs and Private Foundations” (NYU Tax Forum, 2023), “A Brief Review of the Curious Saga of In re Grand Jury” (ABA Tax Section May Meeting, 2023), “APA and Tax Practice” (NYU Tax Forum, 2022), “Owe the IRS? Passports at Risk Under New Code Sec. 7345” (Journal of Tax Practice and Procedure, 2016), and numerous other works on tax controversy, criminal tax, penalties, captive insurance, FBAR/FATCA compliance, and related topics presented for the ABA, NYU Tax Forum, the Strafford Group, the Pacific Tax Institute, and other organizations.

• Experience

John draws on almost three decades of practice and experience in tax law to develop legal theories and strategies in defense of his clients, with a focus on tax controversy and criminal tax matters. His firm, Colvin + Hallett, practices in areas including IRS audits, IRS appeals, tax litigation, criminal tax defense, voluntary disclosures and international compliance, tax advice and expert witness services, IRS collection, and Washington State audits and appeals. He keeps a close watch on developments in tax law and has been deeply engaged in precedent-setting litigation and regulatory comment work, as reflected in his extensive ABA Tax Section service and his national speaking and writing on subjects ranging from the Anti-Injunction Act and accuracy and preparer/promoter penalties to captive insurance audits, foreign-related penalties, and privilege issues in criminal investigations.

 

Kathleen Claussen, Esq., Professor of Law; Anne Fleming Research Professor | Georgetown Law

Kathleen Claussen is Professor of Law and the Anne Fleming Research Professor at Georgetown University Law Center, and a leader in international economic law and procedure who has served as arbitrator, counsel, expert, public servant, and teacher. Her expertise covers several topics of international law, especially trade, investment, international business, and labor; dispute settlement and international dispute bodies; national security and cybersecurity law; and administrative law issues surrounding U.S. foreign relations and transnational agreements. Professor Claussen has testified before the U.S. Congress and the European Parliament on topics related to trade agreements, U.S. tariff laws, and executive power, on which she is a leading authority. Since 2024, she has been Managing Faculty Co-Director of Georgetown’s Institute of International Economic Law, overseeing the Institute’s programming, budget, and administration, and she is co-founder of SAILS: the Consortium for the Study and Analysis of International Law Scholarship.

• Education & Credentials

Professor Claussen holds a B.A. from Indiana University, an M.A. from Queen’s University Belfast, and a J.D. from Yale. At Yale, she served on the board of the Yale Law Journal and was Editor-in-Chief of the Yale Journal of International Law, and she was awarded the Jerome Sayles Hess Fund Prize for excellence in international law and the Howard M. Holtzmann Fellowship in international dispute resolution.

• Recognition & Leadership

One of Professor Claussen’s articles on international investment disputes, The International Claims Trade, was awarded the Smit-Lowenfeld Prize in International Arbitration. In 2024, she was one of four individuals named by the White House to the International Centre for Settlement of Investment Disputes (ICSID) Panel of Conciliators. In 2021, she was appointed co-Editor-in-Chief of the Journal of International Economic Law (Oxford University Press), and in 2025 she was elected to the editorial board of the American Journal of International Law (Cambridge University Press). She has held visiting and fellowship appointments at numerous institutions worldwide, including Northwestern University Pritzker School of Law, the University of Cambridge Lauterpacht Centre for International Law (as a Brandon Fellow), the Graduate Institute of International and Development Studies in Geneva, the iCourts Center of Excellence at the University of Copenhagen, the George C. Marshall Center for Security Studies, the University of Zurich and Collegium Helveticum, and the World Trade Institute; in 2024 she was a Fernand Braudel Senior Fellow at the European University Institute, and in 2025 the Allen and Gledhill Visiting Scholar at Singapore Management University. Her academic work has appeared in the Yale Law Journal, the Stanford Law Review, the Columbia Law Review, the University of Chicago Law Review, and the Virginia Law Review, among others, and she is regularly consulted as an expert by media outlets including the Wall Street Journal, Marketplace, Bloomberg, and the Financial Times.

• Professional Involvement

Professor Claussen holds several leadership positions within international law and arbitration professional associations. She is a member of the Academic Council of the Institute for Transnational Arbitration and the Academic Forum on Investor-State Dispute Settlement and appears on multiple international arbitration rosters maintained by governments for their state-to-state disputes. Her recent governance appointments include the American Society of International Law (ASIL) International Economic Law Interest Group, the ASIL Executive Council & Executive Committee, and the Junior International Law Scholars Association. She is an Adviser for the American Law Institute’s Restatement on Foreign Relations Law and a member of the Global Future Council on International Trade and Investment for the World Economic Forum. She blogs at Lawfare, Just Security (where she is a member of the Editorial Board), and the International Economic Law & Policy Blog.

• Experience

Professor Claussen has served as an arbitrator, as counsel, or as counsel to the tribunal in more than a dozen international trade and investment cases. Before joining the academy, she was Associate General Counsel at the Office of the U.S. Trade Representative (USTR) in the Executive Office of the President, where she represented the United States in trade dispute proceedings and served as a legal advisor in international trade negotiations, and she worked on economic security issues on behalf of USTR at the National Cyber Investigative Joint Task Force. In 2020–2021, she was an invited member of the Biden-Harris Transition Team, covering trade, commerce, and development agencies. Earlier in her career, she was Legal Counsel at the Permanent Court of Arbitration in The Hague, where she advised on disputes between countries and on investment and commercial arbitrations involving countries and international organizations, and she clerked for the Honorable David F. Hamilton of the U.S. Court of Appeals for the Seventh Circuit.

 

Nita Asher, Esq., Principal | Washington National Tax Office, PwC

Nita Asher is a licensed attorney and a Principal in the Washington National Tax Office of PwC, within the firm’s International Tax Services practice, where she advises both U.S. and foreign-based companies on a wide range of international tax issues including financings, treaty qualification, and cross-border restructurings, with a particular focus on inbound multinationals. She advises companies on the impacts of tax policy, such as the implementation of the Tax Cuts and Jobs Act of 2017 (TCJA), and issues related to technical corrections, administrative guidance, and legislative changes to various provisions. Prior to rejoining PwC, she served as Legislation Counsel for the Joint Committee on Taxation (JCT), a nonpartisan committee of the United States Congress, where she was heavily involved in the development of the TCJA.

• Education & Credentials

Nita earned her bachelor’s degree from the University of North Carolina, a JD from North Carolina Central University School of Law, and a Master of Laws in Taxation from Georgetown University Law Center. She is a licensed attorney.

• Recognition & Leadership

Nita serves on the board of directors of Byte Back, a nonprofit organization. She is also a recognized commentator on international tax policy, appearing as a featured guest on PwC’s Cross-border Tax Talks podcast to discuss developments including the Stock Buyback Excise Tax enacted under the Inflation Reduction Act and provisions affecting inbound multinationals.

• Professional Involvement

Nita is a member of PwC’s Washington National Tax Services International Tax Services practice and a frequent speaker on international tax matters, including as a featured guest on PwC’s Cross-border Tax Talks podcast. She serves on the board of directors of Byte Back. The UNC Tax Center lists her among its affiliated members.

• Experience

Nita advises both U.S. and foreign-based companies on a wide range of international tax issues, including financings, treaty qualification, and cross-border restructurings, as well as on the impacts of tax policy such as the implementation of the TCJA and issues related to technical corrections, administrative guidance, and legislative changes. Prior to rejoining PwC, she served as Legislation Counsel for the Joint Committee on Taxation, where she was heavily involved in the development of the TCJA; in that role she met with taxpayers and their representatives to understand their concerns, translated those concerns to the Congressional tax-writing committee and Treasury staff, and assisted with the development of draft technical corrections meant to carry out the TCJA. Earlier in her career, she held International Tax roles at PwC before her government service.

DAY 1, THURSDAY, JUNE 25, 2026

WELCOME – OPENING REMARKS | 8:00am – 8:05am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

SESSION 1 – TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I | 8:05am – 8:30am

Amid an unprecedented federal workforce reduction, continuing IRS funding cuts, and dissolution of the DOJ Tax Division, today’s panels provide a comprehensive update on developments and priorities across the Treasury Department, DOJ Tax Division, and IRS relating to enforcement and compliance.

Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA

 

SESSION 2 – A VIEW FROM THE TOP – A CONVERSATION WITH IRS CEO FRANK BISIGNANO | 8:30am – 9:05am

IRS CEO Frank Bisignano shares his perspective on the agency’s strategic direction, operational priorities, and modernization efforts, addressing resource constraints, technology transformation, workforce initiatives, and the agency’s approach to enforcement and taxpayer service.

Moderator: Michael J. Desmond, Esq., Member and Tax Department Chair, Miller & Chevalier, Chartered, Washington, DC
Hon. Frank J. Bisignano, Chief Executive Officer, Internal Revenue Service, Washington, DC

 

SESION 3 – UPDATES FROM THE IRS COMPLIANCE OPERATIONS | 9:05am – 10:00am

As the IRS seeks to maximize human capital, tools, technology, and process efficiencies for sound tax administration encompassing both service and compliance, a panel of IRS compliance executives provides insight into IRS operations, resources, and priorities.

Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY
Lia Colbert, Commissioner, Small Business/Self-Employed Division, Internal Revenue Service,
Washington, DC
Mabeline Baldwin, CPA, Acting Commissioner, Large Business and International Division,
Internal Revenue Service, Washington, DC
Edward R. Killen, Esq., Commissioner, Tax Exempt and Government Entities,
Internal Revenue Service, Washington, DC
Erick Martinez, Acting Director, Whistleblower Office, Internal Revenue Service, Washington, DC

 

Break | 10:00am – 10:10am

 

SESSION 4 – UPDATE FROM THE US TAX COURT AND THE IRS OFFICE OF CHIEF COUNSEL | 10:10am – 10:55am

This panel provides insight into the Tax Court’s operations, pending cases, and challenges in the current resource-constrained environment, and discusses the IRS Office of Chief Counsel’s leadership, staffing, workload, priorities, and field counsel’s role advising Exam and Appeals.

Moderator: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC
Moderator: Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY
The Hon. Patrick J. Urda, Chief Judge, United States Tax Court, Washington, DC
Kenneth J. Kies, Esq., Acting Chief Counsel, Internal Revenue Service; Assistant Secretary, Tax Policy, US Department of the Treasury, Washington, DC

 

Break | 10:55am – 11:05am

 

SESSION 5 – ERC – FROM AMENDED RETURNS TO THE COURTROOM | 11:05am – 12:00pm

This panel explores the current landscape of Employee Retention Credit claims, including recent trends in audits, administrative appeals, and pending litigation, managing the risk of parallel proceedings, and best practices and strategies for substantiating and defending claims.

Moderator: Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY
Megan E. Marlin, Esq., Principal, PwC, Washington, DC
Daniel Graham Strickland, Esq., Partner, Holland & Knight, Washington, DC
Leila D. Carney, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
Eric Hylton, National Director, alliant, Washington, DC

 

Lunch | 12:00pm – 1:00pm

 

BREAK OUT SESSIONS | 1:00pm – 1:50pm

 

TRACK I

SESSION 6 – PUERTO RICO, USVI, AND MALTA – OH MY!

This panel reviews taxpayer arguments on Puerto Rico and USVI bona fide residency, income-sourcing positions, and Malta pension plans, the IRS and DOJ response, trends in audits, appeals, civil litigation, parallel criminal investigations, and strategies for managing disputes.

Moderator: Elizabeth J. Stevens, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
Joseph A. DiRuzzo, III, Esq., CPA, Partner, Margulis Gelfand DiRuzzo & Lambson, Fort  Lauderdale, FL
Phillip Colasanto, Esq., Senior Associate, Withers Bergman, New York, NY
Daniel N. Price, Esq., Managing Member, Law Offices of Daniel N. Price, San Antonio, TX

 

Break | 1:50pm – 2:10pm

 

BREAK OUT SESSIONS | 2:10pm – 3:00pm

 

TRACK I

SESSION 7 – HIGH WEALTH AUDITS – THE GREATEST HITS (SECA, AIRCRAFT)

As the IRS leverages data analytics to target high-wealth taxpayers, this panel examines examinations into pass-through entities, trusts, private aircraft, limited partner interests, self-employment tax, and shareholder loans, plus taxpayer selection, audit procedures, and defense best practices.

Moderator: Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY
Elizabeth Julia Smith, Esq., Counsel, Skadden, Arps, Slate, Meagher & Flom, Boston, MA
Kevin Spencer, Esq., Partner, White & Case, Washington, DC
Katherine Jordan, Esq., Counsel, Miller & Chevalier, Chartered, Washington, DC

 

Break | 3:00pm – 3:20pm

 

BREAK OUT SESSIONS | 3:20pm – 4:10pm

 

TRACK I

SESSION 8 – FACING THE INEVITABLE – UPDATE ON ESTATE AND GIFT TAX CONTROVERSIES

As the IRS continues targeting wealth transfer strategies and estate and gift planning, this panel features leading practitioners and litigators analyzing the most significant developments over the past year in these high-stakes, high-value tax controversies.

Moderator: Mary E. Wood, Esq., Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX
John W. Porter, Esq., Senior Partner, Baker Botts, Houston, TX
Kathryn Meyer, Esq., Founder & Principal Attorney, Kathryn Meyer Law, PC, Alexandria, VA
Kelley C. Miller, Esq., Partner, Loeb & Loeb, McLean, VA

Break | 4:10pm – 4:30pm

 

BREAK OUT SESSIONS | 4:30pm – 5:30pm

 

TRACK I

SESSION 9 – CHALLENGING CIVIL TAX PENALTIES AND INTEREST – REASONABLE CAUSE, 7508A, AND MORE

This panel reviews the current penalty and interest landscape, dissecting the legal standards for establishing reasonable cause across non-compliance scenarios and analyzing Section 7508A disaster-related relief, including what must be filed by July 10, 2026.

Moderator: Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Michelle Abroms Levin, Esq., Shareholder, Dentons Sirote, Huntsville, AL
Melissa L. Wiley, Esq., Partner, Kostelanetz, Washington, DC
Aaron Esman, Esq., Member, Ziering & Esman, New York, NY
Josh O. Ungerman, Esq., CPA, Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX

 

DAY2, FRIDAY, JUNE 26, 2025

 

SESSION 1 – TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II | 8:30am – 9:00am

WELCOME ABOARD! A CONVERSATION WITH THE DOJ CIVIL DIVISION TAX LITIGATION BRANCH

With civil tax litigation now under the new DOJ Civil Division Tax Litigation Branch, inaugural head Joshua Wu discusses the office’s creation, mission, role in refund litigation, early priorities, and what the structural shift means for practitioners.

Moderator: Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Joshua Wu, Esq., Deputy Assistant Attorney General for the Tax Litigation Branch, US Department of Justice, Civil Division, Washington, DC

 

Break | 9:00am – 9:10am

 

SESSION 2 – FOLLOWING THE MONEY: A CONVERSATION WITH JAROD KOOPMAN, CHIEF, IRS CRIMINAL INVESTIGATION | 9:10am – 9:40am

IRS-CI Chief Koopman discusses the agency’s staffing, resources, global footprint, and enforcement priorities, focusing on how CI identifies and develops cases involving complex financial transactions, digital assets, and cross-border activity, plus investigative trends and interagency coordination.

Moderator: Don Fort, CPA, Senior Investigator, Kostelanetz, Washington, DC
Moderator: Guy Ficco, CFE, Senior Investigator, Kostelanetz, Washington, DC
Jarod Koopman, Chief, Criminal Investigation Division; Chief Tax Compliance Officer,
Internal Revenue Service, Washington, DC

 

Break | 9:40am – 9:50am

 

SESSION 3 – NEW DOJ NATIONAL FRAUD ENFORCEMENT DIVISION | 9 :50am – 10 :20am

As DOJ intensifies its crackdown on financial fraud, this panel offers a rare chance to hear from Department leadership about the new National Fraud Enforcement Division’s mission, leadership, staffing, resources, enforcement priorities, and achievements combatting criminal tax violations.

Moderator: Karen E. Kelly, Esq., Partner, Kostelanetz, Washington, DC
Stephen Weiss, Esq., Associate Deputy Attorney General, Office of the Deputy Attorney General, US Department of Justice, Washington, DC

 

Break | 10:20am – 10:35am

 

SESSION 4 – A LOOK INSIDE TREASURY: A CONVERSATION WITH SHELLEY LEONARD, DEPUTY TAX LEGISLATIVE COUNSEL | 10:35am – 11:05am

Deputy Tax Legislative Counsel Shelley Leonard provides a look inside Treasury’s role in offering legal and policy advice on tax legislation, regulations, and guidance, addressing current legislative and regulatory priorities, the rulemaking process, and real-world impacts of recent changes.

Moderator: Scott Levine, Esq., Partner, Baker McKenzie, Washington, DC
Shelley Leonard, Esq., Deputy Tax Legislative Counsel, Office of Tax Policy, US Department of the Treasury, Washington, DC

 

Break | 11:05am – 11:15am

 

SESSION 5 – LEADING THE CHARGE: A CONVERSATION WITH ERIN COLLINS, NATIONAL TAXPAYER ADVOCATE | 11:15am – 11:45am

National Taxpayer Advocate Erin Collins provides an inside look at the current state of tax administration, the impact of the 2026 filing season, NTA’s June Objective Report to Congress, the Taxpayer Assistance and Service Act, and protecting taxpayer rights.

Moderator: Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA
Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC

 

Lunch | 11:45am – 12:10pm

 

SESSION 6 – GUIDING THE EXEMPT ORGANIZATION IN AN ERA OF ENHANCED ENFORCEMENT | 12:10pm – 1:10pm

With exempt organizations facing unprecedented scrutiny under Executive Orders, this panel examines current audit trends, compliance challenges, and key risk areas including governance, unrelated business income, and operational compliance, plus strategies for examinations and raising constitutional challenges.

Moderator: Meghan R. Biss, Esq., Partner, Loeb & Loeb, Washington, DC
Susanne Sachsman Grooms, Esq., Partner, Cooley, Washington, DC
Casey A. Lothamer, Esq., Senior Counsel, Loeb & Loeb, Washington, DC
Michelle McCarthy, Esq., Senior Manager, RSM US, Hartford, CT

 

BREAK OUT SESSIONS | 1:30pm – 2:20pm

 

TRACK I

SESSION 7 – CLIENTS, CRYPTOCURRENCY, AND CONTROVERSIES – HEAR FROM THE EXPERTS

As the IRS evolves its digital asset enforcement, this panel explores pressing cryptocurrency controversy issues, including substantive tax questions, reporting obligations, valuation challenges, and audit trends, plus practical strategies for advising clients in both civil and potential criminal contexts.

Moderator: Michael Waalkes, Esq., Associate, Kostelanetz, Washington, DC
Philipp Behrendt, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Sean P. McElroy, Esq., Partner, Fenwick & West, Seattle, WA
Amber R. Salotto, Esq., Managing Director, RSM US, Washington, DC

 

Break | 2:20pm – 2:35pm

 

BREAK OUT SESSIONS | 2:35pm – 3:35pm

TRACK I

SESSION 8 – DON’T FORGET THE SALT: HOT TOPICS IN SALT COMPLIANCE, ADMINISTRATION AND AUDITS *ETHICS

In an era of economic nexus and aggressive state authorities, this panel examines state and local audit trends including nexus determinations, apportionment disputes, and data analytics, plus strategies for multistate controversies, coordinating with federal proceedings, and ethical issues.

Moderator: Debra Silverman Herman, Esq., Partner, Hodgson Russ, New York, NY
Catherine Chiou, Esq., Managing Director, Andersen Tax, New York, NY
Richard L. Jones, Esq., Partner, Sullivan & Worcester, Boston, MA
Jeremy Abrams, Esq., Managing Member, ABRAMS TAX LAW, Jersey City, NJ

 

Break | 3:35pm – 3:50pm

 

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK I

SESSION 9 – LEARNING FROM LEARNING RESOURCES: UPDATE ON TARIFF ENFORCEMENT AND REFUNDS

Following the Supreme Court’s 6–3 decision holding that IEEPA does not grant the President tariff power, this panel examines the Court’s analysis, its effect on customs duties, and the decision’s impact on refund claims, enforcement, and litigation strategy.

Moderator: Deanne Morton, Esq., Managing Director, Andersen Tax, San Francisco, CA
Stephen Josey, Esq., Counsel, Vinson & Elkins, New York, NY
Gray Proctor, Esq., Counsel, Kostelanetz, Atlanta, GA
John Colvin, Esq., Partner, Colvin + Hallett, Seattle, WA
Kathleen Claussen, Esq., Professor of Law; Anne Fleming Research Professor, Georgetown Law, Washington, DC
Nita Asher, Esq., Principal, Washington National Tax Office, PwC, Washington, DC