Partner
Tax
“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. She has extensive experience representing clients in federal and state tax audits, administrative appeals, and litigation, including before the U.S. Tax Court and federal district courts and courts of appeal. Adriana has particular experience in advising clients in controversy matters 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.
Adriana’s matters cover a wide variety of tax issues such as transfer pricing, worthless stock deductions, partnership allocations, basis adjustments under subchapter K, foreign tax credits, bonus depreciation, and employment tax issues. She has particular experience in matters involving tax insurance.
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.
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
Education
Admissions
Events
Vinson & Elkins Sponsoring and Speaking at TEI Annual Conference
Vinson & Elkins is a platinum sponsor of the 2026 TEI Annual Conference, taking place October 18–21 in Nashville, Tennessee. …
October 18–21, 2026
October 18–21, 2026 • 1-minute read
Events
Adriana Wirtz to Speak at TEI’s Audit and Appeals Seminar
Partner Adriana Wirtz will speak at the Tax Executives Institute’s (TEI) 2026 Audits & Appeals Seminar on Wednesday, September 9, …
September 9, 2026
September 9, 2026 • 1-minute read
Events
Vinson & Elkins Sponsoring and Speaking at the 91st Annual API Federal Tax Forum
The firm is a Platinum Sponsor of American Petroleum Institute’s (API) 91st Annual Federal Tax Forum taking place April 21 …
April 21, 2026
April 21, 2026 • 1-minute read
Events
Vinson & Elkins Partners to Join TEI’s 2026 Midyear Conference
Vinson & Elkins is a platinum sponsor of the 2026 Tax Executives Institute (TEI) Midyear Conference. The conference will explore …
March 16, 2026
March 16, 2026 • 1-minute read
Events
Partner Kathy Pakenham is speaking at the ABA’s 2025 Criminal Tax Fraud and Tax Controversy Conference on Saturday, December 13 at 8:45 a.m. PST.
December 13, 2025
December 13, 2025 • 1-minute read
Awards & Rankings
The Legal 500 US 2026 recommended Vinson & Elkins as a leading law firm in 47 practice categories. In total, …
June 10, 2026
June 10, 2026 • 3-minute read
Awards & Rankings
Vinson & Elkins announced today that it achieved 20 Band 1 rankings in Chambers USA 2026: Nationwide: Energy Transition; Energy: …
June 4, 2026
June 4, 2026 • 3-minute read
Awards & Rankings
The Legal 500 US 2025 recommended Vinson & Elkins as a leading law firm in 43 practice categories. In total, 133 attorneys are recognized, many in more than one category. Vinson & Elkins attorneys earned multiple special designations, such as “Leading Trial Lawyer,’ “Hall of Fame,” “Leading Partner,” “Next Generation Partner,” and “Leading Associate.”
June 11, 2025
June 11, 2025 • 3-minute read
Awards & Rankings
Vinson & Elkins announced today that it achieved 18 Band 1 rankings in Chambers USA 2025: Nationwide: Energy: Oil & Gas (Regulatory & Litigation); Energy: Oil & Gas (Transactional); Energy Transition; Offshore Energy; Projects: Oil & Gas; Projects: Power & Renewables: Transactional New York: Bankruptcy/Restructuring: Highly Regarded Texas: Bankruptcy/Restructuring; Capital Markets: Debt & Equity; Corporate/M&A: The Elite; Environment: Mainly Transactional; Litigation: Securities; Real Estate; Real Estate: Zoning/Land Use; Tax; Technology: Corporate & Commercial Texas: Austin & Surrounds: Corporate/M&A Texas: Dallas, Fort Worth & Surrounds: Employee Benefits & Executive Compensation Of the firm’s 167 individual lawyer rankings, 16 were newly added in 2025. Some lawyers are ranked in more than one category.
June 5, 2025
June 5, 2025 • 3-minute read
Awards & Rankings
The Legal 500 US 2024 recommended Vinson & Elkins as a leading law firm in 44 categories. In total, 131 attorneys are recognized, many in more than one category. Vinson & Elkins attorneys earned 27 special designations, such as “Hall of Fame,” “Leading Lawyer,” “Next Generation Partner,” and “Rising Star.”
June 12, 2024
June 12, 2024 • 3-minute read
our People
Please note that any communication with Vinson & Elkins via e-mail through this website does not constitute or create an attorney-client relationship with V&E. Please do not send any confidential information. A conflicts-of-interest procedure must be completed by V&E prior to establishment of an attorney-client relationship. When you execute an engagement letter from V&E you will be our client, and you may then exchange information freely with a V&E attorney.
By clicking “Accept,” you agree that we may review any information you transmit to us. You recognize that our review of your information, even if it is highly confidential and even if it is transmitted in a good faith effort to retain us, does not preclude us from representing another client directly adverse to you, even in a matter where that information could and will be used against you.
