Adriana Wirtz
The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, New York 10036
Tax controversies require a unique blend of technical tax experience, business-mindedness, government insight, and strong advocacy skills. Clients turn to us for our ability to provide practical advice on how to resolve their most complicated tax problems. Adriana focuses her practice on tax controversy and litigation. She represents clients at all phases of a tax controversy from audit through litigation, including before the IRS Office of Appeals, US Tax Court, and US district courts of appeal, as well as before state taxing authorities and state courts. Adriana represents large corporate taxpayers and partnerships and has particular experience in advising clients in audits and disputes arising under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and more recently the Bipartisan Budget Act of 2015 (BBA). She has represented clients in the energy, real estate, life sciences, mining and software industries. She has particular experience in matters involving tax insurance.
Adriana’s matters cover a wide variety of tax issues such as transfer pricing, debt-equity classification, partnership allocations, worthless stock deductions, basis adjustments under IRC section 743, foreign tax credits, business aircraft related matters, bonus depreciation, charitable contribution deductions, and employment tax issues.
Prior to joining V&E, Adriana served as an attorney advisor to Judge Carolyn P. Chiechi of the US Tax Court from 2007 to 2009. Adriana is recognized in Tax: Controversy (Nationwide) by Chambers USA 2025 where one client notes “Adriana is not only outstanding in advising on tax matters, but she is an enjoyable person to work with.” She has also been recognized as a “Leading Partner” by Legal 500 U.S.
Experience Highlights
Representing large partnership before IRS Appeals in dispute involving novel issues under the BBA
Obtained favorable resolution for supermajor oil and gas company in partnership tax dispute before U.S. Tax Court arising from divestment of joint venture interest
Trial counsel in $740 million novel partnership tax case before U.S. Tax Court involving the economic substance doctrine and a facial challenge to the validity of the IRS’s Partnership Anti-Abuse regulation
Representing large corporation in interest netting claim before US Court of Federal Claims
Obtained full concession by IRS in BBA partnership examination concerning the tax treatment of certain transfers of partnership interests
Obtained full concession before IRS Appeals of proposed disallowance of worthless stock deduction
Favorably resolved U.S. Tax Court matter involving substantial transfer pricing dispute of multinational company
Obtained nearly full concession before IRS Appeals in real estate company’s dispute surrounding equity compensation of officers and other employees
Obtained full concession by IRS in connection with Bank Secrecy Act examination of cryptocurrency company
Obtained full concession by New York State Department of Taxation and Finance in audit challenging taxpayer’s position that it was not responsible for the collection of New York sales and use tax
Obtained favorable settlement on behalf of major pharmaceutical company in arbitration involving purchase price allocation dispute
Obtained full concession by IRS in examination of technology company’s classification of workers as independent contractors
Credentials
- Georgetown University Law Center, LL.M. Taxation with distinction, 2009
- Seton Hall University School of Law, J.D. cum laude, 2007
- Seton Hall University, B.A. summa cum laude, 2004
- Attorney adviser to Judge Carolyn P. Chiechi of the U.S. Tax Court, 2007–2009
- Chambers USA, “Up and Coming” in Tax: Controversy (Nationwide), 2024 and 2025
- Legal 500 U.S., “Next Generation Partner” in U.S. Taxes: Contentious, 2018–2023; “Leading Partner” in U.S. Taxes: Contentious, 2024 and 2025
- Selected to the New York Rising Stars list, Super Lawyers (Thomson Reuters), 2014–2017
- American Bar Association
- New Jersey
- New York
- U.S. Court of Appeals for the Second Circuit
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. Tax Court
- Rankings & AwardsJune 11, 2025
- Rankings & AwardsJune 5, 2025
- InsightMarch 6, 2025
- InsightJanuary 13, 2025
V&E Tax Update
- Event RecapNovember 7, 2024
- InsightJuly 3, 2024
V&E Tax Update
- InsightJuly 1, 2024
V&E Tax Update
- InsightJune 18, 2024
V&E Tax Update
- Rankings & AwardsJune 12, 2024
- Rankings & AwardsJune 6, 2024
- Event RecapMay 8, 2024
- InsightOctober 9, 2023
V&E Tax Update
- Rankings & AwardsJune 12, 2023
- Press ReleaseJanuary 30, 2023
- “Practical Issues with BBA Audits,” 76th Annual Virginia Conference on Federal Taxation, June 6, 2025 (speaker)
- “Navigating the New Tariff Landscape,” The Association of International Energy Negotiators (AIEN) U.S. Chapter Event, May 13, 2025 (co-speaker)
- “Tariffs and Transfer Pricing,” 90th Annual API Federal Tax Forum, April 22, 2025 (co-speaker)
- “What Every Tax Department Needs to Know About Tariffs,” Tax Executives Institute (TEI) Webinar, April 15, 2025 (co-speaker)
- “Ethics for the In-House Tax Practitioner,” Tax Executives Institute (TEI) 2024 Ethics Webinar Series: Ethics CPE for Tax Professionals, December 10, 2024 (co-speaker)
- “Hot Topics in Federal Tax Litigation,” Tax Executives Institute (TEI) – Houston Chapter Tax Controversy Roundtable Luncheon, December 4, 2024 (co-speaker)
- “Tax Inquiries, Audits and Regulatory Challenges – What Should We Expect?,” V&E Energy Transition & IRA Conference, November 7, 2024 (co-speaker)
- “Implications of the IRS’s Strategic Plan on Tax Planning and Controversy,” Tax Executives Institute (TEI) Audit and Appeals Seminar, September 10, 2024 (co-speaker)
- “Prevailing Wage & Apprenticeship, Domestic Content & Energy Community Bonuses and Tax Controversies & Audits,” V&E Energy Transition & IRA Conference, May 8, 2024 (co-speaker)
- “Managing Statutes of Limitation: Requests to Extend, Exceptions to the General Rules, and Refund Claims,” Tax Executives Institute (TEI) – Houston Chapter Tax School, February 29, 2024 (co-speaker)
- “Federal and International Updates,” Tax Executives Institute (TEI)/Thomson Reuters Year-End Corporate Tax Roundup, December 19, 2023 (co-speaker)
- “Increased Audit Scrutiny of Complex Business Arrangements and Partnerships: Trends and Management Strategies,” Tax Executives Institute (TEI) Annual Conference, October 23, 2023 (co-speaker)
- “Navigating Large Partnership Audits,” V&E Navigating Series CLE, October 12, 2023 (co-speaker)
- “The IRS’s New Enforcement Initiative: Navigating the Audit Process,” V&E Energy Series CLE, June 14, 2023 (co-speaker)
- “IRA Clean Energy Credits & Anticipated Enforcement,” New York University’s (NYU) Tax Controversy Forum, June 9, 2023 (co-speaker)