US taxes: contentious

David Aughtry

Shareholder

Larry Campagna

Managing Shareholder

Scott Michel

Member

Jean Pawlow

Partner, Tax Controversy

Victoria Gu

Associate

Michael Scarduzio

Michael J. Scarduzio focuses his practice on US and international tax matters, particularly civil and criminal tax litigation. From audit to litigation, he represents taxpayers in all phases of tax controversy, including novel issues of first impression such as financial hedging transactions using a captive insurer, US tax implications of a foreign master-feeder fund’s investment activities and matters arising under Internal Revenue Code (IRC) Sections 7216 and 7212(a). Read full biography: https://www.mwe.com/people/scarduzio-michael-j/

Terrell Ussing

Terrell Ussing is a partner in the Washington D.C. office of Gibson, Dunn & Crutcher and a member of the firm’s Global Tax Controversy and Litigation Practice Group.  His practice focuses on federal tax controversy and litigation. Terrell counsels multinational companies across all industries in all aspects and phases of tax controversy and litigation.  He has significant experience representing clients on a range of complex domestic and international tax issues, with an emphasis on transfer pricing.  His transfer pricing experience includes complex transfer-pricing litigation, planning, and risk assessment at the federal, international and state levels.

Niles Elber

Member

Diana Erbsen

Partner

David Foster

David Foster is a partner in the Tax Practice Group in the Washington, D.C., office of Kirkland & Ellis LLP. David advises a broad range of clients, including large corporations, private equity firms and hedge funds, partnerships, estates, exempt organizations and individuals, many of whom are subject to the IRS’ Global High Wealth initiative. His practice covers a diverse range of tax issues, including international tax and transfer pricing, TEFRA and BBA partnership audit and litigation procedures, taxation of financial products, estate and gift taxes, deferred compensation, voluntary disclosures and criminal tax. A former Supreme Court clerk, David has prepared briefs and argued before many of the federal courts of appeals. Prior to joining Kirkland, he obtained a rare taxpayer victory striking down a Treasury Regulation in Hewitt v. Commissioner, 21 F.4th 1336 (11th Cir. 2021). He also represented five former IRS commissioners in a D.C. Circuit amicus brief in Loving v. IRS in support of licensing standards for tax return preparers, as well as the American College of Tax Counsel in amicus briefs in the Tax Court and the Supreme Court. David lectures regularly to in-house tax departments and professional associations. He is a fellow of the American College of Tax Counsel and the American Bar Foundation. He also served as chair of the D.C. Bar’s Tax Audits and Litigation Committee and as co-chair of the ABA Tax Section’s Privileges Subcommittee of the Civil and Criminal Tax Penalties Committee. David has repeatedly been ranked in Chambers USA, Chambers High Net Worth, The Best Lawyers in America and The Legal 500 United States, and was previously recognized as one of Washington, D.C.’s Trending 40 Lawyers Under 40 by Legal Bisnow. He has also been included in Washingtonian’s Top Lawyers list since 2018.

Natalie Keller

Natalie Keller’s practice focuses on all aspects of tax controversies, including audits, administrative appeals and litigation. She has litigated cases in the US Tax Court, Court of Federal Claims, district and bankruptcy courts and courts of appeal. She also advises US and foreign multinational clients on intercompany transfer pricing planning and compliance, resolution of transfer pricing audits and competent authority. Her transfer pricing experience includes significant cases in the automotive, consumer electronics and pharmaceutical industries.

Brian C. McManus

Tax Partner

Saul Mezei

Saul Mezei is a partner in the Washington D.C. office of Gibson, Dunn & Crutcher and a member of the firm’s Global Tax Controversy and Litigation Practice Group.  His practice spans the federal tax controversy area and focuses on international tax and transfer pricing.  He has substantial experience advising clients at all stages of federal tax controversy, from audit and administrative appeals to trial and judicial appeals.

Jaime Vasquez

Shareholder

Juan F. Vasquez, Jr.

Shareholder

Jane Wells May

Jane Wells May focuses her practice on state and local tax matters. She represents businesses in connection with tax controversies at the audit, administrative and judicial levels around the United States. Her clients include companies in manufacturing, retailing, pharmaceuticals, financial services, agribusiness, food and beverage, health care, energy, technology and insurance industries. Jane has served on the Firm’s Management and Compensation Committees, on the Executive Committee and as the global head of the Firm’s Tax Practice. Jane has successfully litigated state and local tax matters raising a variety of statutory and constitutional issues. She has defended numerous internet sellers in several states against cases brought under state whistleblower statutes, including the Illinois False Claims Act, alleging fraudulent failures to collect and remit use tax. Jane also advises business clients on tax planning matters and represents athletes and entertainers in connection with employment contract issues. Jane is a co-founder of Tax in the City: A Woman’s Tax Roundtable®, which consists of women tax professionals with an interest in discussing substantive tax issues in a collegial and confidential setting, and which meets regularly in Chicago and New York. While in law school, Jane was senior articles editor of the Vanderbilt Law Review and a member of the Moot Court Board.

Adriana Wirtz

Adriana focuses her practice on tax controversy and litigation. She represents clients at all phases of a tax controversy from audit through litigation, including before the IRS Office of Appeals, US Tax Court, and US district courts of appeal, as well as before state taxing authorities and state courts. Adriana has represented clients in the energy, real estate, life sciences, mining and software industries. She has particular experience in matters involving tax insurance. Adriana’s matters cover a wide variety of tax issues such as transfer pricing, debt-equity classification, partnership allocations, business aircraft related matters, foreign tax credits, charitable contribution deductions, and employment tax issues. She also has significant experience in defending taxpayers against the imposition of civil penalties, including negligence, valuation misstatement, fraud and information return penalties. Prior to joining V&E, Adriana served as an attorney advisor to Judge Carolyn P. Chiechi of the US Tax Court from 2007 to 2009. While attending law school, she completed an externship with the Internal Revenue Service Office of Chief Counsel.