Zhanna Ziering

Practice Areas

Tax Litigation

Tax Controversy

Career

Zhanna A. Ziering, a tax controversy and litigation attorney, is a Member in the Firm’s New York office. Ms. Ziering’s practice focuses on representing individual and entity clients in civil and criminal tax disputes with federal and state governments as well as in regulatory proceedings. She defends both individual and entity taxpayers before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators.

Ms. Ziering advises taxpayers in connection with various tax issue, including those arising in connection with domestic and offshore income and assets, cryptocurrency, and U.S. tax and regulatory reporting requirements. She approaches each of her client engagements with empathy and kindness and develops a strategy for dispute resolution by taking the client’s views, needs, and resources into consideration. When faced with alternatives for dispute resolution, Ms. Ziering discusses the various available options, and the benefits and drawbacks of each such option, with the clients and works together with them to develop the approach tailored to that particular client and situation.

Ms. Ziering strives to resolve every tax dispute that her clients are facing amicably and efficiently while zealously advocating on her clients’ behalf. Her significant experience in representing clients in various stages of a tax dispute allows her to aptly navigate the procedural hurdles and achieve best results possible under the circumstances for each client.

A well-regarded member of the legal community, Ms. Ziering is actively engaged in American Bar Association, Section of Taxation. She currently serves as the Chair of Court Practice and Procedure Committee. Ms. Ziering is also a sought-after speaker and writer on various topics relating to tax controversy and litigation. She is a co-author of the Bloomberg BNA’s Tax Management Portfolio, Report of Foreign Bank and Financial Accounts.

Together with Guinevere Moore, Ms. Ziering represented the Center for Taxpayer Rights as amicus curiae for the U.S. Supreme Court in Bittner v. United States and Bedrosian v. United States. An avid supporter of the arts, Ms. Ziering had offered pro bono tax representation to artists from a diverse range of industries, such as film, music, and fashion. She also provided counsel to low-income taxpayers with a broad range of tax issues through Duke University School of Law’s Low-Income Taxpayer Clinic and New York University School of Law’s Tax Clinic.

Ms. Ziering lives in New Jersey with her husband, two rambunctious boys, and a Chocolate Labrador, named Mr. Chance Broadway. Ms. Ziering is a native Russian speaker and insists on reading all the great Russian literature in its original language.

Professional Memberships

• Fellow, American College of Tax Counsel

• American Bar Association, Section of Taxation

• Current Vice-Chair of the Court Practice and Procedure Committee

• Former Vice-Chair of the Court Practice and Procedure Committee

• Former Co-Chair of Subcommittee on Offshore Enforcement for Civil and Criminal Tax Penalties Committee

• New York State Bar Association

• Federal Bar Association

Publications

• Zhanna Ziering and Aaron Esman pen American Bar Association Section of Taxation comments on proposed amendments to the Tax Court rules of practice and procedure, May 25, 2022.

• “Decrypting The New IRS Cryptocurrency Compliance Letters”, with Victor A. Jaramillo, Law360 Tax Authority, August 7, 2019

• “Deal or No Deal: The Unknown Cost of the IRS’s New Voluntary Disclosure Practice”, with Arielle Borsos, White Collar Crime Committee Newsletter, February 28, 2019

• “INSIGHT: Last call for OVDP: Use It or Lose It”, with Ben Eisenstat, Bloomberg Tax: Daily Tax Report, April 20, 2018

• “IRS Launches Issue Based Corporate Compliance Campaigns”, Global Tax Weekly, February 16, 2017

• Report of Foreign Bank and Financial Accounts (FBAR), (Book), Co-Author, Bloomberg BNA’s Tax Management Portfolio, June 29, 2016,

• “U.S. Offshore Account Enforcement Issues”, CCH’s Journal of Tax Practice & Procedure, September 30, 2014

• “The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court,” The Practical Tax Lawyer, December 1, 2012

• Comments to the Proposed Amendments to the Rules of the United States Tax Court, American Bar Association, March 7, 2011

• Comments to the Proposed Amendments to the Rules of the United States Tax Court, American Bar Association, May 27, 2009

• Selected Recent Developments in Administrative Practice, American Bar Association (May Meeting, Administrative Practice Committee), May 8, 2009