Elizabeth Nelson, Esq., J.D., LL.M. is a Senior Tax Attorney at Leading Tax Group whose professional background spans federal and California tax controversy, U.S. Tax Court matters, IRS audits and Appeals, payroll tax disputes, innocent spouse matters, and representation involving California tax agencies, including the Franchise Tax Board (FTB), Employment Development Department (EDD), and California Department of Tax and Fee Administration (CDTFA).
Her tax-law background combines advanced academic training, federal Tax Court experience, teaching, published tax commentary, professional leadership, and experience with substantial individual and business tax controversies.
Elizabeth earned her LL.M. in Taxation from New York University School of Law after receiving her J.D., cum laude, from the University of San Diego School of Law.
Earlier in her career, she was awarded a clerkship with the United States Tax Court, where her responsibilities included researching and writing Tax Court opinions involving regular, small, and special-project cases.
This combination of tax-law scholarship and practical controversy experience informs her work with taxpayers confronting complicated federal and California tax disputes.
Elizabeth’s experience includes matters involving:
Her experience across both federal and California tax agencies can be particularly relevant when a taxpayer’s problem is not confined to a single taxing authority.
A distinguishing part of Elizabeth’s professional background is her experience with the United States Tax Court.
Elizabeth was awarded a clerkship with Senior Judge Theodore Tannenwald Jr. of the U.S. Tax Court. During her 1987–1988 clerkship, she researched and wrote Tax Court opinions involving regular, small, and special-project cases.
Her professional vitae specifically identifies her work involving Metzger v. Commissioner, 88 T.C. 834 (1987).
Before receiving the Tax Court clerkship, Elizabeth earned her J.D. cum laude, graduating within the top 9% of her class at the University of San Diego School of Law. According to her professional vitae, she was the first USD graduate appointed to a clerkship with the U.S. Tax Court.
This background provides Elizabeth with experience not only in tax law itself but also in the processes through which federal tax controversies can be researched, argued, reviewed, and decided.
IRS tax controversies can range from disputed assessments and audits to Appeals, collection matters, payroll tax liabilities, penalties, and litigation.
Elizabeth’s representative experience includes IRS matters involving individuals, businesses, real estate developers, entrepreneurs, nonprofit organizations, physicians, entertainers, and private foundations.
Her reported representative matters have included disputes involving:
The appropriate strategy in an IRS controversy depends on the facts, procedural stage, supporting evidence, applicable tax law, and available administrative or judicial remedies.
Payroll tax controversies can create significant financial and legal problems for businesses, nonprofit organizations, and individuals who may potentially be considered responsible for unpaid employment taxes.
Elizabeth has professional experience involving substantial IRS payroll tax matters.
Representative matters supplied by Elizabeth include reported outcomes involving multimillion-dollar payroll tax assessments and penalties, Trust Fund penalties, nonprofit payroll tax liabilities, and Offers in Compromise.
Her professional writing also includes the publication “Resolving Payroll Tax Liability,” published in The Commercial Factor Magazine.
This combination of case experience and published commentary makes payroll tax controversy an important area of Elizabeth’s professional authority.
The Trust Fund Recovery Penalty (TFRP) can potentially create personal liability for certain individuals when employment taxes that should have been collected and paid to the federal government remain unpaid and applicable legal requirements are satisfied.
Elizabeth’s representative matters include a reported $1.2 million Trust Fund penalty matter that was reduced to $0.
Because TFRP matters can involve questions concerning responsibility, willfulness, business operations, payroll practices, and individual involvement, they can differ significantly from ordinary individual income-tax collection cases.
Innocent spouse matters represent another significant area of Elizabeth’s experience.
These cases may arise when one spouse seeks relief from joint federal tax liability under applicable innocent spouse provisions.
Elizabeth’s representative matters include innocent spouse disputes resolved through IRS Appeals, the U.S. Tax Court, and other IRS proceedings.
Examples provided in her representative matters include reported outcomes involving assessments of:
Several were reportedly reduced to zero, while the $22 million matter was reportedly reduced to $1,500 in U.S. Tax Court.
These representative matters illustrate the potentially significant financial consequences involved in complex innocent spouse disputes.
Representative matters are provided for informational purposes. Every case depends on its individual facts, applicable law, evidence, and procedural circumstances. Past results do not guarantee future outcomes.
Elizabeth also has experience with matters involving the California Franchise Tax Board (FTB).
The FTB administers California personal and corporate income taxes and can conduct audits, issue assessments, impose applicable penalties, and pursue collection actions.
Elizabeth’s reported FTB representative matters include:
Taxpayers facing both IRS and FTB issues should recognize that federal and California tax controversies involve separate agencies, procedures, deadlines, and potential remedies.
Elizabeth’s California tax experience also includes representation involving the California Department of Tax and Fee Administration (CDTFA).
The CDTFA administers California sales and use taxes and various other tax and fee programs. For businesses, a CDTFA sales tax audit can involve detailed examination of sales records, exemptions, reported transactions, accounting records, and supporting documentation.
Elizabeth’s representative CDTFA matters include reported audit outcomes involving:
Her work in this area also extends to tax education and thought leadership.
Elizabeth is the author of the new book:
How to Win a CDTFA Sales Tax Audit
Her CDTFA experience makes sales-tax audits and California tax controversy important areas of her professional profile at Leading Tax Group.
Before publication, Leading Tax Group should add the book’s publication date, publisher, ISBN, and official book URL if available.
Elizabeth also represents taxpayers in matters involving California’s Employment Development Department (EDD).
EDD employment-tax disputes can involve payroll taxes, worker classification, employment-tax assessments, audits, penalties, and Appeals.
Representative EDD matters supplied by Elizabeth include:
This experience complements Elizabeth’s federal payroll-tax work and provides her with experience involving employment-tax controversies at both federal and California levels.
Tax controversies involving nonprofit organizations can raise issues beyond ordinary business income taxes.
Elizabeth’s representative experience includes matters involving:
Reported representative matters include a $1.8 million nonprofit payroll tax liability resolved to $175,000 through an Offer in Compromise, a $2.2 million UBIT matter reduced to zero in audit, and proposed assessments involving private-foundation self-dealing and Section 501(c)(3) UBIT reportedly reduced to zero.
Elizabeth’s experience also includes federal tax controversies involving businesses, entrepreneurs, real estate developers, and other commercial taxpayers.
Representative matters supplied by Elizabeth include:
These matters demonstrate the variety of factual, financial, procedural, and legal issues that can arise in business tax controversies.
IRS Appeals provides taxpayers with an administrative forum for attempting to resolve certain disputes without litigation.
Elizabeth has both practical and published experience involving IRS Appeals.
Her publication history includes:
“Settling with the IRS in Appeals: The New Importance of the APA”
published in the CCH Journal of Tax Practice and Procedure.
Her representative matters also include substantial disputes resolved through IRS Appeals, particularly in the area of innocent spouse relief.
For taxpayers, understanding the distinction between an IRS examination, IRS Appeals, and U.S. Tax Court can be important when determining what options remain available after disagreeing with an IRS determination.
Elizabeth’s professional background extends beyond tax representation.
She has served as an Adjunct Professor at Chapman University School of Law’s LL.M. Tax Program, where her work has included divorce taxation and development and coordination of the Chapman Tax Professionals Panel.
Her earlier academic experience includes teaching tax courses through:
At UCSB, she taught Tax I and Tax II within CPA and CFP certificate programs.
Her combination of tax practice and teaching experience provides an additional dimension to her work explaining complex tax issues to taxpayers, professionals, and other audiences.
Elizabeth’s tax-related publications include:
The Commercial Factor Magazine
Co-author
Is IRS Rule Invalid for Failure to Comply With the Congressional Review of Agency Rulemaking Act?
CCH Journal of Tax Practice and Procedure
Co-author
Book
Her publications cover topics including payroll tax liability, offshore accounts, IRS administrative rules, IRS Appeals, entity structuring, and California sales-tax audits.
Elizabeth’s tax presentations have included:
Presented in connection with the American Bar Association Tax Section Spring Meeting, Cal Poly Pomona Tax Institute, and Pasadena CPA/EA Society.
Presented through the American Bar Association Tax Section and Long Beach CPA/EA Society.
Presented to South Bay CPAs.
These engagements demonstrate experience communicating complex tax issues to tax professionals as well as handling them in practice.
Elizabeth’s professional activities have included:
She has also served as a tax advisor to Sheriff Leroy D. Baca through the Los Angeles County Sheriff’s Department Multi-Faith Executive Council.
New York University School of Law
LL.M. in Taxation
May 1997
University of San Diego School of Law
Juris Doctor, Cum Laude
June 1986
Senior Tax Attorney Specializing in CDTFA, EDD, and FTB Representation
Advanced Tax Law Knowledge. Decades of Legal Scholarship. Strategic Tax Resolution.
Elizabeth Nelson, Esq., is a tax attorney whose professional background combines advanced tax-law education, federal tax-court experience, legal scholarship, and extensive involvement in tax education and professional organizations. Her credentials include a Master of Laws in Taxation from New York University School of Law and a Juris Doctor degree, earned cum laude, from the University of San Diego School of Law.
At Leading Tax Group, Elizabeth brings a strong foundation in tax law and legal analysis to complex tax matters. Her professional background includes a clerkship with the United States Tax Court, academic appointments in graduate tax-law education, and publications addressing IRS procedures, payroll tax liabilities, and federal tax policy.
Her experience in legal research, tax education, and professional leadership provides a valuable perspective on the rules and procedures that shape federal tax disputes and resolution strategies.
Federal Tax Law and Legal Expertise
Elizabeth’s professional background reflects a sustained focus on federal taxation, tax procedure, and the interpretation of tax law. Her legal education and judicial clerkship have provided a foundation for analyzing statutory requirements, administrative procedures, and the legal issues that can arise in disputes involving tax liabilities.
Her published work addresses several important areas of tax practice, including payroll tax liability, offshore account reporting, IRS appeals, and challenges involving federal agency rulemaking. These subjects are particularly relevant to understanding how tax obligations are assessed, how taxpayers interact with the IRS, and how legal procedures may affect available resolution options.
Her academic and professional activities also demonstrate experience engaging with specialized tax questions, including partnership taxation, innocent spouse issues, and tax audits involving complex provisions of the Internal Revenue Code.
United States Tax Court Clerkship
One of the distinguishing elements of Elizabeth’s professional background is her clerkship with the United States Tax Court during 1987–1988. She received the position through an appointment by Senior Judge Theodore Tannenwald, Jr., becoming the first graduate of the University of San Diego School of Law appointed to a Tax Court clerkship.
During this appointment, she researched and wrote Tax Court opinions involving regular, small, and special-project cases. Her résumé references Metzger v. Commissioner, 88 T.C. 834 (1987), affirmed at 845 F.2d 1013 (3d Cir. 1988), as part of her clerkship experience.
This judicial experience provides an important dimension to her background in tax law, particularly in understanding legal research, judicial analysis, and the application of federal tax principles.
Advanced Education in Taxation
Elizabeth earned her Master of Laws in Taxation (LL.M. Tax) from New York University School of Law in May 1997. This advanced degree reflects specialized graduate-level study in taxation.
She earned her Juris Doctor, cum laude, from the University of San Diego School of Law in June 1986, graduating in the top nine percent of her class. Her academic record also includes a graduate fellowship in the LL.M. Tax Program and research assistant work for the Honorable Theodore Tannenwald, Jr., of the United States Tax Court.
Her combination of advanced tax education, legal research, and judicial experience forms a substantial academic and professional foundation for her work in taxation.
Teaching, Professional Leadership, and Tax Education
Elizabeth has maintained an active role in tax education and professional organizations.
Since 2009, she has served as an adjunct professor in Chapman University School of Law’s LL.M. Tax Program, teaching divorce taxation and developing and coordinating the Chapman Tax Professionals Panel.
From 2012 to 2015, she served as Vice Chair of the American Bar Association’s Tax Section, Individual and Family Income Committee. She also served as Secretary of the Beverly Hills Bar Association’s Tax Section from 2009 to 2010.
Her additional professional involvement includes serving as a board member of the Southern California Chapter of the International Factoring Association since 2020.
Earlier teaching appointments included tax instruction at the University of California, Santa Barbara, where she taught in the Business Management and Law Department’s CPA and CFP certificate programs, and at Santa Barbara College of Law.
These roles reflect sustained engagement with tax education, professional development, and the exchange of technical knowledge among tax practitioners.
Publications and Contributions to Tax Law
Elizabeth has written and contributed to publications addressing federal taxation, IRS procedures, and tax controversy matters. Her documented publications include:
Her presentation experience includes sessions on winning a Section 469 audit, taxation of domestic partnerships, innocent spouse matters, and domestic partnerships. These subjects reflect a broad engagement with tax law, audit issues, and specialized tax-planning considerations.
A Research-Driven Approach to Tax Matters
Elizabeth’s professional background combines judicial research, advanced tax education, academic teaching, and published analysis of tax controversy issues. This combination supports a methodical approach to understanding tax problems, examining applicable legal rules, and evaluating procedural considerations.
For individuals and businesses facing federal tax questions, this background is relevant to understanding the importance of accurate documentation, compliance obligations, IRS procedures, and informed consideration of available resolution pathways.
Every tax matter depends on its specific facts, applicable law, and procedural circumstances. A careful assessment of those elements is essential when evaluating potential strategies for addressing tax liabilities or disputes.
Connect With Leading Tax Group
Facing an IRS audit, payroll tax liability, an offshore reporting concern, or another federal tax issue? Contact Leading Tax Group to discuss your circumstances and explore the options that may be available.
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Elizabeth’s experience includes IRS tax controversy, audits, Appeals, Tax Court matters, payroll tax, innocent spouse cases, business tax disputes, and California tax matters involving the FTB, EDD, and CDTFA.
Yes. Her representative experience includes CDTFA sales-tax audit matters, and she is the author of How to Win a CDTFA Sales Tax Audit.
Her supplied representative matters include California EDD payroll-tax audits and Appeals.
Yes. Her representative experience includes FTB penalties, settlements, levy disputes, and California tax matters associated with innocent spouse cases.
Yes. Earlier in her career, Elizabeth clerked for Senior Judge Theodore Tannenwald Jr. at the U.S. Tax Court, where she researched and wrote Tax Court opinions.
Her professional background includes IRS Appeals matters, and she has published on settlement within the IRS Appeals process.
Yes. Her representative matters include several substantial innocent spouse cases handled through IRS Appeals, U.S. Tax Court, and other IRS proceedings.
Yes. Her representative matters include IRS and EDD payroll-tax disputes, Trust Fund penalty matters, and nonprofit payroll-tax controversies. She has also published on resolving payroll-tax liability.
Her professional vitae identifies her as an adjunct professor in Chapman University’s LL.M. Tax Program and lists earlier tax-instructor positions at UCSB and Santa Barbara College of Law.
Her professional background combines an advanced LL.M. in Taxation from NYU, U.S. Tax Court clerkship experience, tax-law teaching, published tax commentary, professional leadership, and practical experience involving IRS and California tax controversies.
Elizabeth Nelson, Esq., J.D., LL.M. is a Senior Tax Attorney at Leading Tax Group whose experience includes IRS tax controversy and representation involving the California Franchise Tax Board (FTB), Employment Development Department (EDD), and California Department of Tax and Fee Administration (CDTFA).
Her professional background combines advanced tax-law education, U.S. Tax Court experience, teaching, publications, professional leadership, and representative matters involving individuals, businesses, nonprofit organizations, payroll tax disputes, innocent spouse cases, sales-tax audits, and other federal and California tax controversies.