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