Emily A. Parker

Emily Parker is a tax attorney in Holland & Knight's Dallas office. Ms. Parker represents taxpayers in Internal Revenue Service (IRS) audits and appeals proceedings, state tax audits and hearings, and federal and state tax refund and deficiency litigation.

In addition, Ms. Parker advises on federal income tax and Texas tax planning, with experience in taxation of natural resources and partnership and corporate transactions involving the petroleum industry. Ms. Parker has represented clients in a number of precedent-setting cases that decided important industry issues and developed previously unsettled issues of tax law.

Industry sources say:

She is a strong practical lawyer with broad experience, particularly on oil and gas taxation matters.

– Chambers USA – America's Leading Lawyers for Business 2021 guide

Ms. Parker previously served as acting chief counsel and deputy chief counsel for the IRS.

Representative Experience

• Representing a publicly traded financial services company in an appeals proceeding relating to various tax advantaged transactions
• Representing a publicly traded homebuilder in an appeals proceeding relating primarily to proposed disallowance of net operating loss carryovers
• Representing a major petroleum company in an appeals proceeding relating to deduction of intangible drilling and development cost for deep water offshore platforms
• Representing an estate in an audit and appeals proceeding relating to a claim for refund of more than $300 million in federal estate tax
• Representing a major utility company in audit and appeals proceedings involving a variety of tax issues
• Represented a sports franchise and owner in an IRS audit and appeals proceeding involving various issues, including issues unique to the sports business
• Acted as an expert witness for a major investment banking firm regarding structure and effect of tax advantaged investments, and as an expert witness for a bankrupt company regarding a number of consolidated return related issues
• Represented a publicly traded exploration and production company in an IRS audit and appeals proceeding regarding various issues, including tax treatment of a volumetric production payment
• Represented a retailer in a U.S. Tax Court proceeding regarding arm's length pricing of insurance commissions received by the retailer in connection with customer insurance reinsured with a company owned by the retailer
• Represented a U.S. corporation in a U.S. Tax Court trial and U.S. Court of Appeals for the Fifth Circuit appeal by the IRS relating to withholding on guarantee fees paid to its Mexican parent