About Adriana Wirtz

Adriana Wirtz focuses her practice on tax controversy and litigation. She represents clients at all phases of a
tax controversy from audit through litigation, including before the IRS Office of Appeals, US Tax Court, US
district courts, US bankruptcy courts and US courts of appeal, as well as before state taxing authorities and
state courts. Adriana has represented clients in the energy, real estate, life sciences, mining and software
industries.
Adriana’s recent matters cover a wide range of tax issues such as transfer pricing, debt-equity classification,
charitable contribution deductions, economic substance issues, foreign tax credits and employment tax
issues. She also has particular experience in defending taxpayers against the imposition of civil penalties,
including negligence, valuation misstatement, fraud and information return penalties.
Adriana advises clients on tax compliance and procedural matters, including information reporting and
withholding obligations, statutes of limitations and collection matters. She also advises clients in connection
with voluntary disclosures to the IRS and state agencies.
Prior to joining Cooley, Adriana served as an attorney adviser to Judge Carolyn P. Chiechi of the US Tax
Court from 2007 to 2009. While attending law school, she completed an externship with the Internal Revenue
Service Office of Chief Counsel.