Debra_Estrem

Debra K. Estrem J.D.

Managing Director, Private Wealth Tax Controversy, Deloitte Tax

Debra leads the National Private Wealth Tax Controversy team for Deloitte Tax, advising on IRS controversy matters throughout the country and globally. After law school, she experienced 15 years at IRS Chief Counsel where she litigated a wide variety of individual, estate, tax-exempt, corporate, and partnership tax matters. She has more than 20 published Tax Court opinions. As a Special Trial Attorney for the IRS, Debra litigated and resolved many high-profile cases at the Service. She was lead counsel in numerous trials, including the _Seagate_ case, involving whether stock options must be shared in cost-sharing arrangements, the _Georgiou_ case, involving constructive dividend and consolidated return issues, and the _Fu_ case, which resolved a major evidence-gathering dispute. Since coming to Deloitte over 22 years ago, Debra has handled significant IRS-related matters for individuals, estates, tax-exempt entities, corporations, and partnerships. She now specializes in IRS audit defense of high-wealth individuals, private businesses and tax-exempt entities. She has been involved with many of the largest such disputes in the country, and clients rely on her wealth of practical and technical knowledge. She is particularly experienced with valuation, hobby loss, employment tax, penalties, and the unique issues faced by estates and tax-exempt entities. In addition, she is an expert in obtaining closing agreements, technical advice, and pre-filing agreements, defending IRS examinations, and conducting regular and Fast Track IRS Appeals, as well as other types of mediation. She regularly performs IRS readiness projects for individuals and related entities, tax-exempt entities, and estates. Because of her litigation background, she is regularly called upon to assist with trials in the Tax and District Courts.

Appearances