Victoria A.


Tory O’Connor primarily represents corporate taxpayers in tax controversy and tax litigation matters. Tory advises clients in disputes with the IRS from audit-level proceedings and IRS appeals to litigation. She manages all aspects of audits, including information document requests (IDRs), protests, appeals and settlements. Tory represents clients in litigation in the various available tax forums and has participated in refund suits in several matters before the U.S. District Courts and appeals to U.S. Courts of Appeals.

In Tory’s litigation practice, she manages complex discovery including numerous expert witnesses and large document review and productions, including electronic discovery.  She is a member of the firm’s E-Discovery and Information Management team. 

Beyond her litigation experience, Tory also provides tax-planning advice in corporate and international tax areas, including representing clients in acquisitions, sales, and corporate restructurings.  She also advises clients in exempt organization matters, assisting clients in obtaining, maintaining and reinstating tax-exempt status.

Selected Experience

Sutherland represents Delphi in $26 million FICA refund suit.
Sutherland represents Delphi in a refund suit seeking the return of approximately $26 million in FICA taxes.
Sutherland represents international insurance company in tax litigation regarding $306 million tax refund.
Sutherland represents an international insurance company in a refund suit that it filed for its 1997 tax year, seeking the return of approximately $306 million in tax, penalties and interest. The case involves a number of issues, including whether the company is entitled to certain foreign tax credits that it claimed in various cross-border financing transactions.
Sutherland represents Procter & Gamble in $435 million tax refund suit.
Sutherland was lead counsel for Procter & Gamble in a multimillion dollar tax refund suit. The court recently entered summary judgment for Procter & Gamble on an issue of first impression involving the proper treatment of intercompany sales for research credit purposes.

Awards and Rankings

Named to the Capital Pro Bono High Honor Roll (2012)

Professional Activities

Member, Tax Section, American Bar Association
Member, Tax Section, District of Columbia Bar
Member, Tax Section, Georgia Bar

  • J.D., Georgetown University Law Center, Member, Law and Policy in International Business Journal
  • B.A., magna cum laude, Georgetown University
Bar Admissions
  • District of Columbia
  • Georgia

Our Story

Sutherland Asbill & Brennan LLP is a law firm helping the Fortune 100, industry leaders, sector innovators and business entrepreneurs solve their biggest challenges and reach their business goals. Dedicated to unfaltering excellence in client service, we are known for our business savvy and industry intelligence, providing creative and custom solutions for each of our clients. Industry and business experience makes the difference for our clients.

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Mark D. Wasserman, Managing Partner
Atlanta, GA
© 2014 Sutherland Asbill & Brennan LLP.
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