17th Annual Tax Controversy Forum 2025 – Track III (Presented by NYU School of Professional Studies)

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.

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.

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.

Liz Askey is Of Counsel in the Tax Controversy and Litigation practice at Skadden, Arps, Slate, Meagher & Flom LLP, based in the firm’s Washington, D.C. office. She has more than three decades of experience advising on tax controversy matters, including examinations, appeals, alternative dispute resolution, and litigation. She also has extensive experience in controversy mitigation strategies, including private letter rulings, closing agreements, prefiling agreements, the Industry Issue Resolution program, and regulatory and legislative tax policy advocacy.

Dan Price’s practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney in the IRS Office of Chief Counsel, and his experience as a former trial attorney, supervisory trial attorney, and Special Assistant United States Attorney gives him a distinctive perspective on tax controversy and tax administration. For federal tax and federal immigration matters, he accepts clients nationally.

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies. She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with an office in Chicago. Guinevere has over fifteen years of experience helping taxpayers resolve significant disputes with the IRS and state tax agencies, and she routinely represents taxpayers in high-stakes criminal and civil tax disputes. She takes a holistic approach to representing clients, getting to know each client and developing a deep understanding of their needs and preferences before developing a strategy for the case. She is also a frequent speaker and author, routinely publishing articles and speaking at conferences around the world on tax controversy and tax litigation, including in Forbes, Bloomberg, and Tax Notes.

Rod Rosenstein is a member of the North America Litigation & Government Enforcement Practice Group and the Global Dispute Resolution Practice Group, based in Baker McKenzie’s Washington, DC office. He is co-chair of the firm’s National Security Practice, a team of former US government officials, former prosecutors, trade practitioners, and data privacy and cyber lawyers. During the administrations of Presidents George W. Bush, Barack Obama, and Donald Trump, Rod held senior political appointments as the Deputy Attorney General of the United States, US Attorney for the District of Maryland, and Principal Deputy Assistant Attorney General for tax enforcement in the US Department of Justice. He previously served as an Assistant US Attorney and a Criminal Division trial attorney, and represented the US government in 23 jury trials while arguing 21 civil and criminal cases in appellate courts and the US Supreme Court. He also served as a law clerk to Judge Douglas Ginsburg of the US Court of Appeals for the District of Columbia Circuit. As the second-highest ranking Department of Justice official, Rod managed a USD 28 billion budget and oversaw 115,000 employees in the Department’s litigating divisions, law enforcement agencies, and US Attorney’s Offices.

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.

Dean Zerbe is National Managing Director of alliantgroup and a partner at Zerbe, Miller, Fingeret, Frank & Jadav LLP, a law firm specializing in tax whistleblowers and tax litigation. He is also a Senior Policy Advisor to the National Whistleblower Center. Dean spent more than 25 years in congressional service, including as Senior Counsel and Tax Counsel for the Chairman of the U.S. Senate Finance Committee, Senator Charles E. Grassley, from 2001 to 2008. In that role, he was the driving force behind the legislation that created the modern IRS Whistleblower Office and expanded the rewards for tax whistleblowers. He has represented several tax whistleblowers — including Bradley Birkenfeld, who received the largest individual whistleblower award in U.S. history ($104 million) — and led the landmark Tax Court case Whistleblower 21276-13W v. IRS (2017), which established the definition of ‘collected proceeds’ under the whistleblower law. He holds a J.D. from George Mason University and an LL.M. in Taxation from New York University (notably also holding a BFA in Film Production from NYU). He was recognized by National Journal as one of the ‘Hill 100’ top congressional staffers.

Andy Weiner is Counsel with Kostelanetz LLP, based in the firm’s Washington, D.C. office. He focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. A Fellow of the American College of Tax Counsel, Andy is a frequent writer and speaker on tax issues. He has handled a wide diversity of matters in areas such as partnership taxation, corporate taxation and reorganizations, taxation of S corporations, tax accounting methods, income tax, gift and estate taxes, and collections, combining a deep knowledge of tax law with extensive litigation and administrative practice experience.

David W. Foster is a partner in the Tax Disputes 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’s Global High Wealth initiative. His practice covers a diverse range of tax issues, including BBA partnership audit and litigation procedures, energy tax credits, international tax and transfer pricing, challenges to tax-exempt status, taxation of financial products, estate and gift taxes, deferred compensation, voluntary disclosures, and criminal tax. A former Supreme Court clerk for Justice Kennedy, David has prepared briefs and argued before many of the federal courts of appeals. He lectures regularly to in-house tax departments and professional associations.

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.

Sanford “Sandy” J. Boxerman is a Shareholder at Neill Schwerin Boxerman, P.C. in St. Louis. Sandy defends individuals and corporations in white-collar investigations and prosecutions, represents taxpayers in civil and criminal tax matters, and advises participants (and would-be participants) in the digital assets space. From 1991 to 1994, he served as an assistant public defender in the City of St. Louis, where he first-chaired numerous jury and bench trials, including two jury trials in one week. In addition to his active law practice, Sandy teaches the tax fraud prosecutions course in the graduate tax program at the Washington University School of Law, and for many years taught the Legal Environment of Business course at the Washington University Olin Business School.

Niles A. Elber, a Member in Caplin & Drysdale’s Washington, D.C., office, has more than 20 years of experience representing clients in civil and criminal tax controversies. His practice is broad, ranging on the civil side from IRS examinations, Appeals matters, collections, and proceedings in federal court, while on the criminal side handling both administrative and grand jury tax investigations. With considerable experience in offshore compliance matters for U.S. taxpayers, Mr. Elber has assisted hundreds of clients with their voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts. He is particularly focused these days on defending clients who find themselves caught up in aggressive IRS campaigns against alleged abusive tax shelters and transactions, and he most recently represented a defendant in one of the largest and most significant tax cases brought by the U.S. Department of Justice in the “conservation easement” area.

Yvonne R. Cort is a Partner at Capell Barnett Matalon & Schoenfeld LLP, where she focuses her practice on resolving federal and New York State tax controversies. For over twenty years, Yvonne has assisted individuals and businesses with IRS and NYS tax matters, including New York State and New York City residency audits, IRS and NYS audits and appeals, unfiled returns, income tax, sales tax, withholding tax, responsible person assessments, liens and levies, tax warrants, innocent spouse relief, voluntary disclosure, installment agreements, and offers in compromise.

Jeffrey M. Sklarz is a Founding Partner of Green & Sklarz LLC, based in New Haven, Connecticut. Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs, including bankruptcy and bankruptcy litigation, creditor/debtor litigation, tax litigation, and commercial litigation. He regularly tries cases and appeals before Connecticut’s state and federal courts and has particular experience regarding the interplay between bankruptcy and tax law. He typically serves as counsel to clients experiencing a wide array of financial challenges, often involving “bet the company” matters.

Kathy Enstrom is the Chief Operating Officer and Director of Investigations for the Moore Tax Law Group, based in Chicago, and a former Executive within Internal Revenue Service Criminal Investigation (IRS CI). Having spent nearly 28 years in federal law enforcement, Ms. Enstrom has expertise in financial crimes, specifically income and employment tax evasion, money laundering, Bank Secrecy Act violations, government assistance fraud, and bank fraud.

Sarah Green is a senior managing associate at Dentons Sirote in Birmingham, Alabama, where she is a member of the Tax practice. With a strong focus on tax controversy and litigation, she represents clients during all phases of federal income tax disputes, including IRS audits, administrative appeals, and court proceedings in the U.S. Tax Court, federal district court, and the U.S. Courts of Appeals. With experience navigating a diverse array of complex tax issues, Sarah focuses on federal and state civil tax controversies, including representing clients in sensitive audits, administrative appeals, and litigation. She also provides tax advice and represents individuals and entities in criminal tax investigations and prosecutions.

S. Starling Marshall is a partner in the Litigation and Tax groups in Crowell & Moring’s New York office. A trial lawyer with over 15 years of experience, she has successfully represented clients before federal and state courts, arbitration panels, and administrative tribunals. When clients face complex commercial and tax disputes, they rely on Starling as their advocate and counselor, and she guides them toward business-minded solutions throughout all phases of an investigation or litigation. In addition to representing clients in all stages of litigation, she guides clients through complex IRS audits and administrative appeals, provides tax-related advice, conducts internal investigations, and represents individuals and corporate entities in criminal tax matters.

Tino Lisella is a Shareholder at Carlton Fields, based in West Palm Beach, and a former FINRA enforcement director and former federal tax prosecutor. Tino’s practice focuses on securities enforcement, civil and criminal tax controversy, and white collar litigation. He represents individuals and entities in complex securities matters and government investigations, as well as regulatory investigations and enforcement, and brings firsthand knowledge of the boots-on-the-ground strategies and priorities that prosecutors and FINRA enforcement attorneys use to build their cases—and the most effective strategies to defend against them. Tino also has significant experience in matters involving vulnerable adults and elderly customers.

Barbara T. Kaplan chairs Greenberg Traurig’s New York Tax Practice and focuses her tax litigation practice on representing domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies, and litigation, including administrative and grand jury criminal tax investigations. Her concentrations include tax compliance counseling, offshore account reporting, sensitive audits, promoter audits, preparer penalties, civil tax controversies, complex tax litigation, criminal tax investigations, voluntary disclosures, tax penalties and procedure, Bank Secrecy Act compliance, Circular 230 violations, ERISA litigation, regulatory investigations, state and local tax, and audits and litigation involving tax-exempt organizations.

Caitlin R. Tharp is a Partner at Steptoe LLP, based in the firm’s Washington, DC office. Caitlin’s multidisciplinary practice focuses on tax controversy, ERISA, and employee benefits, covering both litigation and counseling in those areas. She has more than a decade of experience handling disputes with tax authorities, both at the administrative level and in litigation, having represented clients in IRS examinations, achieved full IRS concessions at IRS Appeals, and resolved taxpayers’ administrative delays with the IRS. Her litigation experience spans all forums for tax disputes—the Tax Court, the Court of Federal Claims, various appellate courts, and federal district courts across the country—and has included challenges to regulations and sub regulatory guidance, the economic substance doctrine, excise taxes, alternative energy tax credits, captive insurance, the employee retention credit, and cross-border transactions.

Justin L. Campolieta is a Partner in the Tax practice at Jones Day, based in the firm’s New York and Miami offices. With two decades of experience as a trial attorney for the Internal Revenue Service (IRS) Office of the Chief Counsel, Justin has overseen the development, litigation, and resolution of some of the largest and most complex tax cases in the United States. He has broad experience with administrative and judicial tax controversies involving a wide variety of procedural and substantive tax issues, including transfer pricing, tax evasion and fraud, financial products, tax treaties, cross-border information sharing, employment tax, collection due process, partnership taxation, administrative law, and a host of corporate and individual income tax issues. For the past decade, his practice has focused primarily on international tax matters, with a concentration on high-stakes transfer pricing controversies, typically involving the transfer and valuation of “crown jewel” intangibles by some of the largest corporate taxpayers in the world.

Andrew Strelka is a partner in Willkie’s Tax Department and Chair of the Tax Resolution Practice Group, based in the firm’s Washington, DC office. Andrew has significant tax experience in a variety of government and private practice roles and is nationally recognized for his work in tax-related disputes, litigation, and investigations. He advises on a comprehensive range of tax controversy matters with particular focus on tax litigation, IRS appeals, exempt organizations, Administrative Procedure Act issues, and transfer pricing issues. His clients span a variety of industries, including global nonprofits, private equity, technology, and global financial institutions.