Patricia Sweeney has practiced exclusively in the area of federal taxation for more than 35 years, advising large U.S. and foreign-based multinationals regarding the resolution of federal tax disputes. She has extensive experience evaluating tax positions, developing strategic responses to Internal Revenue Service (IRS) challenges and resolving federal income tax controversies before the IRS and in court.
Ms. Sweeney's broad range of clients in the automotive, oil and gas, natural resources, chemical, financial, aerospace, utility and telecommunications industries hire her to resolve their most pressing tax controversy problems. The substantive areas in which she successfully represents clients include: tax accounting issues (including depreciation, casualty loss, capitalization, inventory and accrual issues); research and development (R&D) credits, partnership taxation, domestic production deduction issues, transfer pricing, tax structured transactions, taxation of financial instruments, worker classification and foreign tax credits.
Ms. Sweeney regularly assists her clients with IRS examinations, Appeals and other IRS alternative dispute resolution (ADR) procedures, including post-Appeals mediation, Industry Issue Resolution (IIR) Programs and technical advice and Private Letter Ruling (PLR) Requests. Her knowledge of the IRS and Department of the Treasury processes and personnel, as well as her experience litigating tax cases, allows her to develop effective strategies that maximize both successful administrative resolutions and courtroom success. Ms. Sweeney has a talent for developing and leading an integrated team that maximizes the talents and resources of the client's own personnel and other advisors.
Ms. Sweeney served as Chair of the Tax Department and a member of the firm's Executive Committee from October 2008 - June 2015.
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