Senior Attorney (Litigation and Advisory Division), Office of Chief Counsel (Miami office), Internal Revenue Service
What are the challenges of your role at the IRS? What do you like most about it?
I focus primarily on large taxpayers such as partnerships, corporations, and high-net-worth individuals. The bulk of my work is advisory work, although recently I’ve had a bigger focus on litigation cases. The challenge, I would say, is that the landscape of Chief Counsel is changing and we’re doing more litigation work. The learning curve of trying to learn litigation versus advisory is something I worked on when I was a Big Law associate and my practice was all transactional.
But I love the work at the IRS. It’s basically analyzing the tax code and applying the facts. And we advise the agents on the law and a plethora of different issues.
What led you to work as a senior attorney at the IRS?
I externed at Chief Counsel while earning my JD [at the University of Miami School of Law] and I really liked it, but I wanted to give Big Law a try. In the end, I switched over because the work at Chief Counsel was more the work that I wanted to do. Another factor was work-life balance.
Why did you pursue tax law?
I didn’t think that I would ever want to do tax. I just knew I wanted to do corporate transactional work, and someone advised me to take federal income tax because it would be important. I was really, really dreading it. But I took it, and now here I am, years later. Before doing an LLM, I did a lot of research and took more tax courses to make sure that’s what I liked and wanted.
I would just say be open-minded, because I never thought that I would like it at all. Tax is in everything. No matter what you’re dealing with and what sector, tax comes into play.
What advice do you have for law students interested in tax law or government work?
For tax law, my first advice would be to get an LLM. And then for government work, it’s important to know what kind of lifestyle you want and the kind of work that you want to do. In private practice, I was doing M&A work. Here, it’s totally different. I’m advising—it’s more about research, applying the law to the facts, the code.
I do think that trying it all to see what you really like is good advice. I like that even though I’m here, I did Big Law already, because I learned a lot and got that perspective. I would recommend an externship. That’s how I found out about Chief Counsel, which is the largest firm in the world. If you want to try that out first, it opens a lot of doors as well. I loved my externship so much, I knew that I wanted to potentially come back one day.
What was your favorite class at NYU Law?
Taxation of Mergers and Acquisitions with Adjunct Professor Kenneth Heitner ’73, LLM ’77 and Taxation of Financial Instruments with Adjunct Professor Thomas Humphreys LLM ’79 were my favorite classes. I think having an adjunct professor who works at a firm brings really good insight: OK, this is the law, but how is it applied in real-life situations? That really helped me when I started in Big Law, when I got these M&A deals, to be able to put into perspective how it works in real life as opposed to just knowing the code and the law.
What memory from your NYU Law days stands out the most?
When I think of my LLM experience, it was the year that TCJ [Tax Cuts and Jobs Act of 2017] came out. Even the professors were still trying to interpret it and learn it. I mean, it was very, very new. And so that was a cool experience because we were all learning together. But I enjoyed the whole thing.
If you could go back in time, what kind of advice would you give yourself?
I would try to go to more networking events. NYU Law has a huge networking platform, and I wish I had taken more advantage of that. And definitely get to know all your classmates, because it’s very likely that you could run into them in the future. I have, and it’s very helpful to know people in different areas. It’s a very good community.
As somebody working in the legal field, in what ways do you think NYU Law graduates are distinct from those from other schools?
At NYU Law they’re very engaged, very passionate about tax law, very knowledgeable. The students work hard. I mean, they’re there because they truly have a passion for tax law. I think NYU has the best tax law community where you’re going to learn the most and get the most out of the courses.
This interview has been condensed and edited.
Posted December 18, 2024