17th Annual Tax Controversy Forum 2025 – Track I (Presented by NYU School of Professional Studies) (Day 2)

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.

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.

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.

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.

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.

Michael Sardar is a partner in Kostelanetz LLP’s New York City office with extensive experience across a wide range of tax controversy and white-collar criminal defense matters. He represents clients in all stages of civil and criminal tax controversies before the IRS, state tax authorities, the Department of Justice, and local prosecutors, and advises taxpayers facing audits and investigations of noncompliance with foreign bank and asset reporting requirements.

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.

Zhanna A. Ziering, a tax controversy and litigation attorney, is the Managing Member of Ziering & Esman PLLC, based in New York City. Ms. Ziering represents individual and entity taxpayers in civil and criminal tax matters before taxing authorities and enforcement agencies, including the Internal Revenue Service, the Department of Justice, and state tax authorities. She has represented clients in federal and state courts, including the United States Tax Court and the Court of Federal Claims. A zealous advocate for her clients, Ms. Ziering assists clients in all stages of the tax controversy and litigation cycle, approaching each client with compassion and understanding and working collaboratively to develop a strategy specifically tailored to the unique needs of each client. She also provides pro bono tax representation to artists across film, music, and fashion, and is committed to defending taxpayers facing penalties for international reporting noncompliance, frequently undertaking projects and cases on a pro bono basis. A native Russian speaker, Ms. Ziering lives in New Jersey.

Fran Obeid is the founder of MFO LAW, P.C. in New York City. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General, and other government agencies. Ms. Obeid has represented numerous clients residing throughout the world with undisclosed offshore accounts, advising on disclosure and compliance alternatives and guiding them through the process, and she defends clients in federal and state audits, including residency and sales tax audits, while advising on how to prevent such audits. She regularly interacts with revenue officers and agents, IRS Appeals officers, IRS Counsel, criminal investigators, Assistant United States Attorneys, and Assistant Attorneys General, taking the right approach to best meet the client’s needs—whether defending a civil examination, criminal investigation or indictment, or subpoena demand.

Joshua D. Smeltzer is an experienced trial lawyer, Board Certified tax law specialist, and trusted advisor to corporations, partnerships, family offices, and high-net-worth individuals, based in Gray Reed’s Dallas and Houston offices. A former trial attorney with the U.S. Department of Justice, Joshua brings more than two decades of government and private-sector experience to high-stakes civil and criminal federal court litigation across the country, with matters ranging from $500,000 to over $1.5 billion. Chair of the Tax Controversy & Litigation practice and co-chair of the firm’s Blockchain and Digital Asset practice, he focuses on distilling highly technical tax, financial, and regulatory issues into clear themes that resonate with judges, juries, and government agencies, and he represents clients through every stage of a controversy with the federal government, including complex litigation in federal district courts, the U.S. Tax Court, and other federal forums. His litigation and advisory work spans financial services, private equity, energy, real estate, and emerging technologies such as artificial intelligence and digital assets. A recognized thought leader on tax, corporate governance, digital assets, and regulatory compliance, Joshua serves as editor of Gray Reed’s Dollars & Sense blog and contributes regularly to Forbes and other national publications.

Jonathan Kalinski specializes in both civil and criminal tax controversies, as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets, and provides tax advice to taxpayers and their advisors throughout the world. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters.

Darren Guillot is a National Director at alliantgroup, based in Houston, and a former IRS Commissioner of the Small Business/Self-Employed (SBSE) Division. As an alliantgroup trusted tax advisor and consultant, Mr. Guillot assists small and medium-sized businesses in navigating America’s tax system to secure incentives and credits that stimulate innovation and improve products and services. He also serves them as an expert resource resolving complex compliance and appellate controversies.

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.

Pamela Grewal is a managing director in the US National Tax practice at Andersen, based in San Francisco, California. 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 as she litigated cases for various divisions and advised numerous examination teams on a wide range of issues.

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.

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.

Dan Mayo is a Partner at Withum and leads the firm’s National Tax Services practice. He brings more than 25 years of professional tax experience in federal, international, and financial products taxation, with particular expertise in QSBS, the Employee Retention Credit, mergers and acquisitions, capital markets transactions, and cross-border matters. He also represents individuals and businesses in tax controversies with the IRS and serves as an expert witness in tax-related litigation. Dan is an adjunct tax professor at Georgetown University Law Center, a FINRA-approved arbitrator, and a Forbes contributor covering all things tax. He holds a J.D., cum laude, from Seton Hall University School of Law, an LL.M. in Tax from NYU School of Law, and a B.S. from Rutgers College. Prior to Withum, he gained experience at large law firms, KPMG, and as in-house tax counsel at Citigroup and Barclays/Lehman Brothers.