Diana Erbsen concentrates her practice on federal, state and local tax controversies and tax litigation, including criminal tax matters.
She has significant experience representing clients (public and privately held corporations, as well as partnerships, estates and individuals) in all aspects of sophisticated, challenging tax disputes, at the federal state and local levels.
Diana represents clients in tax disputes with the Internal Revenue Service throughout the United States (including IRS audits and in protests to the IRS Appeals Office) and in matters pending before multiple federal courts (including the United States Tax Court and the Court of Federal Claims). In addition, Diana represents clients who are targets, subjects and witnesses in criminal tax investigations being conducted by the Criminal Investigation Division of the IRS and the Department of Justice.
In state and local controversy matters, Diana represents clients in tax disputes with state and local taxing jurisdictions, including the New York State Department of Taxation and Finance and the New York City Department of Finance.
Diana also represents clients seeking to become compliant with US (as well as state) tax laws regarding international tax issues, including representing clients participating in Voluntary Disclosure Initiatives relating to previously undisclosed foreign financial accounts and in civil tax audits and criminal tax investigations related to these matters.