Roberts & Holland LLP

Ellen Seiler Brody, for more than 20 years, has represented U.S. and international clients in tax controversy matters. Her clients include individuals, trusts, estates, corporations, and partnerships, including audits conducted under the IRS’s centralized audit regime of the Bipartisan Budget Act of 2015. Ellen represents clients during IRS audits and at appeals, as well as in litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, and Federal district courts. She successfully litigated Grecian Magnesite, which overruled a long-standing IRS Revenue Ruling.

Additionally, she is experienced with New York State and City tax controversy, and has represented clients in matters involving personal income tax; corporate franchise tax; general corporation tax; unincorporated business income tax; commercial rent tax; and real estate transfer tax and real property transfer tax.  In these matters, Ellen represents clients during the audit, at conciliation, and in litigation before administrative bodies.

Ellen has co-authored numerous Bloomberg Tax Portfolios (formerly BNA Tax Management Portfolios), including 537 T.M., Qualified Business Income Deduction: Section 199A; 539 T.M., Net Operating Losses — Concepts and Computations; 627 T.M., Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation; 628 T.M., Transferee Liability; 630 T.M., Tax Court Litigation; and 631 T.M., Refund Litigation.

She is a Fellow of the American College of Tax Counsel.

She received a B.S. magna cum laude from the Wharton School of the University of Pennsylvania, and her J.D. cum laude and LL.M. (Taxation) from New York University School of Law, where she was Note and Comment Editor of the Law Review. She is also a Certified Public Accountant.