Diana Erbsen has more than two decades of experience in the tax controversy area, where she focuses on federal, state and local tax controversies, including criminal tax matters. Diana has significant experience representing clients in all aspects of sophisticated, challenging tax disputes. She has been recognized by the American College of Tax Counsel as a Fellow and is a frequent speaker at national tax conferences and forums.
From 2014 to 2017, Diana served as the Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice, a position to which she was appointed by President Barack Obama. In this role, Diana oversaw the Appellate Section (responsible for all appellate litigation, including to the Supreme Court), the Office of Review (responsible for civil settlements), and the Financial Litigation Unit (tasked with collecting judgments secured by the Trial Sections of the Tax Division). Additionally, Diana was actively involved in the management and operations of the Civil and Criminal Sections of the Tax Division and represented the DOJ on the Advisory Committee on Bankruptcy Rules. She was recognized in January 2017 by IRS Chief Counsel William Wilkins, with the Chief Counsel Award (the highest honor that can be conferred by that office) for her leadership and oversight of the Appellate Section. Her contributions to the precedent-setting Altera v. Commissioner case, a model for the government's defense of cases pending in the District Court and the Tax Court, were specifically noted.
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