Another Excellent Result for Emma Smith

Comiter Singer Senior Counsel Emma Smith recently secured a significant victory for a taxpayer in the United States Tax Court, confirming the straightforward and correct tax treatment of a disputed transaction. While the substantive tax issue should never have required litigation, the matter illustrates how today’s IRS environment, marked by backlogs, communication breakdowns, and procedural confusion, can force even clear-cut cases into court when issues are not framed and advanced effectively within the agency.

​What made the difference in this case was not a novel tax argument, but Emma’s deep understanding of IRS procedure and internal processes. Before joining Comiter Singer, Emma spent more than a decade as a trial attorney and later a senior leader within the IRS Office of Chief Counsel, litigating cases in the U.S. Tax Court and advising revenue agents on complex domestic and international issues. That background allows her to anticipate how a case is likely to progress within the IRS, understand who actually makes decisions, and structure the record so that, when communication with the Service is slow or ineffective, the taxpayer’s position is still optimally positioned for resolution.

​In an IRS world where it is increasingly difficult to reach a live person, obtain clear written responses, or correct obvious administrative missteps, having tax counsel who “speaks IRS” is critical. Emma’s experience on the government side gives our clients a practical advantage, from navigating the earliest stages of IRS examination through appeals and, when necessary, Tax Court.

This latest Tax Court result underscores Comiter Singer’s commitment to pairing deep technical tax knowledge with real-world procedural insight to protect taxpayers and bring common-sense outcomes to otherwise needlessly complicated disputes.

If you are faced with a tax controversy, please contact Emma Smith and our other attorneys at (561) 626-2101 to discuss your prospective matter.