Priscilla Ayn Parrett, Counsel at our Portland, San Diego, Los Angeles, and Orange County law offices
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Priscilla Ayn Parrett

Counsel
Biography

Priscilla Ayn Parrett is a seasoned litigator with over a decade of experience handling complex disputes across a range of industries and forums. She draws on her deep trial and advisory background to help clients navigate high stakes matters from early case assessment through resolution. Priscilla has a range of experience with complex business litigation including trademark, contract, and other business disputes.

Priscilla is also an experienced litigator in the federal and state and local tax field. Priscilla has litigated and resolved countless complex federal, state, and local tax disputes for individuals and business entities. As a former IRS Chief Counsel attorney, Priscilla can provide unique insights to assist clients through all stages of federal tax disputes from audit, to appeals, to litigation. Priscilla also has extensive experience handling state and local tax matters including franchise tax, income tax, gross receipts tax, sales and use tax, and other excise tax audits and appeals before various state revenue departments including in California and Oregon. In addition to business tax disputes, Priscilla also represents individuals in their tax disputes at the federal and state and local level. Priscilla has handled multiple high-net-worth individual residency audits as well as general income tax audits.

Before joining the firm, Priscilla served as a partner at a California law firm and as counsel at multiple Am Law 100 firms, where she represented Fortune 500 companies and high-net-worth individuals in complex, multijurisdictional disputes. She also spent several years with the IRS Office of Chief Counsel, where she litigated cases before the U.S. Tax Court and led internal trainings on trial strategy and evidentiary issues. Her experience includes managing all phases of litigation, including depositions, motion practice, discovery, and settlement negotiations.

Credentials

Bar Admissions

  • California
  • Oregon


Court Admissions

  • Supreme Court of California
  • Supreme Court of Oregon
  • United States Tax Court


Education

  • University of California at Los Angeles (UCLA) School of Law (J.D.)
    • UCLA Law Review, Symposium Editor
    • Mock Trial, President
    • Trial Advocacy Competition, Best Attorney Runner Up
  • Rice University (B.A. Political Science, with honors)
    • George R. Brown Forensics Association Speech and Debate, Team Captain
    • 2007 American Forensics Association, National Persuasive Speaking Champion
Experience

Representative Experience

Federal Tax Matters

  • Represented businesses and individuals before IRS audit, appeals, and the United States Tax Court
  • Prepared and negotiated IRS refund claims
  • Worked on complex federal tax issues including micro captive insurance transactions and syndicated conservation easement cases
  • Represented parties in complex federal tax matters involving valuation of large assets
  • Litigated more than 20 cases to trial in the United States Tax Court
  • Handled complex tax levy and lien issues including resolving those through negotiated settlements and collection alternatives
  • Represented clients in voluntary disclosure cases
  • Assisted clients in reviewing offshore account compliance
  • Worked with estates to resolve past tax compliance issues

State and Local Tax Matters

  • Represented business and individuals against the California Franchise Tax Board and the California Department of Tax and Fee Administration in tax audits and appeals
  • Represented businesses and individuals in California State Courts against the California Franchise Tax Board and the California Department of Tax and Fee Administration
  • Represented multiple Fortune 500 companies in complex state tax apportionment and allocation cases
  • Litigated multi-jurisdictional sales and use tax cases regarding the definition of “tangible personal property” as applied to new and emerging technologies
  • Handled employment tax issues before the California Employment Development Department
  • Represented businesses and individuals in California property tax appeals including the valuation of aircraft
  • Provided advice to clients regarding complex Prop 13 property tax issues
  • Provided advice to clients regarding California Documentary Transfer Tax issues
  • Represented businesses against the Oregon Department of Revenue in tax audits and appeals
  • Representing client in Washington sales and use, and business and occupations tax compliance issues
  • Represented businesses against various state and local jurisdictions including Arizona, Colorado, Utah, Louisiana, Florida, Pennsylvania, Missouri, West Virginia, New Jersey, New York, and Illinois
  • Represented clients in utility tax and fee disputes
  • Represented clients in complex state tax levy and lien cases
  • Assisting clients with unclaimed property issues

General Litigation Matters

  • Representing companies in litigation against allegations of fraud, misrepresentation, and breach of contract
  • Representing a manufacturer against breach of warranty claims
  • Representing a client in claims against an insurance company for failure to provide coverage
  • Representing a company in litigation against claims of securities fraud under the Oregon Securities Law
  • Representing a company in litigation against claims of wrongful termination
  • Representing individuals against allegations of the Computer Fraud and Abuse Act
  • Advised clients on trademark violations under the federal Lanham Act
  • Represented clients in Freedom of Information and state law equivalent disputes

Previous Professional Experience

  • Internal Revenue Service Office of Chief Counsel
    • Staff Attorney, Litigation & Advisory Division Counsel (Offshore)
    • Senior Attorney
    • Attorney
    • Law Clerk
  • Vallejo, Antolin, Agarwal & Kanter LLP, Partner
  • Reed Smith LLP
    • Counsel
    • Senior Associate
  • Morrison & Foerster, LLP, Associate

Professional Memberships and Activities

  • California Bar Association
  • Oregon State Bar Association
    • Litigation Law Section
    • Tax Regulation Section

Representative Presentations and Publications