Jennifer Potts Seybold

Jennifer focuses her practice on federal tax controversies and litigation. Drawing from her experience representing the IRS in examinations and litigation, Jennifer brings perspective and insight into resolving her clients’ tax issues. Jennifer also supports the Renewable Energy Tax Team with her knowledge of IRS practice and procedure.

• Works with renewable energy clients to understand and effectively apply the new and expanded energy tax incentives contained in the Inflation Reduction Act (2022), and previously, the Build Back Better proposed legislation.
• Represented a renewable energy plaintiff in a Court of Federal Claims refund suit involving tax credit payments under Treasury’s Section 1603 grant program.
• Represents an energy client in an employment tax examination.
• Serves as a secondary reviewer for Tax Opinions issued to clients in the renewable energy industry.
• Represents clients across a variety of industries in responding to, and seeking abatement of, IRS penalties.
• Represents an institutional client in responding to a third-party IRS summons proceeding.
• Represents clients with respect to conservation easement audits and litigation.
• Represents a Trust in defeating a proposed disclosure penalty.
• Represents a Money Services Business in an IRS Bank Secrecy Act (Title 31) compliance examination.
• Assists clients with navigating the tax implications of the Families First Act and the CARES Act.
• Represents low-income individual taxpayers in IRS proceedings and docketed cases through pro bono representation with the Community Tax Law Project.
• Advised a Section 501(c)(3) charitable organization on UBIT matters.
• As an attorney with the IRS Office of Chief Counsel, Large Business & International division, and the Income Tax & Accounting division of the IRS National Office:
  • Litigated a matter in the US Tax Court involving the cancellation of an Advance Pricing Agreement, and was awarded the IRS Chief Counsel National Outstanding Litigator of the Year Award (2015) following trial;
  • Led an LB&I examination team through the successful development of a Fortune 100 Company’s transfer pricing case; and
  • Advised IRS revenue agents and taxpayers on a variety of technical and procedural tax matters, with a focus on international tax issues, corporate transactional issues, and changes in accounting methods.
• As a senior manager in the National Tax Practice of a Big 4 Accounting Firm:
  • Represented clients in a variety of IRS administrative proceedings to resolve federal income tax issues and abate IRS penalties;
  • Provided counsel on international procedural tax matters for corporations and expatriated individuals; and
  • Advised clients on the impacts of the Centralized Partnership Audit Regime (BBA Partnership Audit Regime).
• In the mergers and acquisitions group of a Big 4 Accounting Firm:
  • Managed tax due diligence examinations for both strategic and private equity buy-side clients, assessing exposure risks in federal and state income tax, employment tax, property tax, sales and use tax, and escheatable property;
  • Structured U.S. and cross-border transactions; and
  • Advised clients on transactional considerations such as net operating loss limitations, certain acquisition gross-up calculations, etc. at both federal and state levels.

• IRS Chief Counsel National Outstanding Litigator of the Year Award (2015)

• Associate, J. Edgar Murdock Inn of Court, US Tax Court
• Federal Bar Association, Tax Section
• Certified Public Accountant (Tennessee – inactive; District of Columbia – inactive)