Kelley C. Miller is a partner with Reed Smith, resident in the firm’s Washington, D.C. office. Her practice focuses on navigating her clients – publicly traded Fortune 25 companies, billion dollar privately held companies, and high-net-worth owners of successful closely held entities – through complex federal and state tax planning, estate and gift planning, and tax controversy matters. She routinely represents clients in difficult audits and examinations before the Internal Revenue Service, including representation before administrative appeals, and, when necessary, litigation of federal and state tax cases in the federal courts and, particularly, the United States Tax Court. Kelley has represented corporations, partnerships, and individuals in all phases of state and federal civil tax controversy, and has advised clients on both civil and criminal tax implications. She has appeared before the Internal Revenue Service, the New Jersey Tax Court, the D.C. Office of Tax and Revenue, the U.S. Tax Court, U.S. district courts, and the U.S. Courts of Appeals for the Fourth and Federal Circuits.

In addition to being nationally recognized for her expertise in federal tax controversy and planning, Kelley routinely advises clients in the cannabis space on issues related to COGS, IRC Section 261, and represents clients before the Internal Revenue Service in audit and examinations relating to these matters, as well as Section 280E and post-Harborside planning.

In addition to her federal and state tax planning and controversies practice, Kelley is part of the Reed Smith COVID-19 response team, addressing federal tax matters arising from the U.S. government’s response to the corona virus.

Kelley is a nationally recognized federal tax attorney who has guided her clients through challenging matters such as disclosure of offshore accounts and unreported income from assets including cryptocurrency. She is also a leading expert on the litigation of complex estate and gift tax controversies involving the Internal Revenue Service, including serving as lead counsel in Estate of Clara M. Morrissette v. Commissioner (USTC Docket No. 4415-14), and currently represents a host of tax-exempt organizations including both foundations and public charities.

Kelley is the recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award and the Thompson Reuters Everyday Hero Award, and was named by Law360 as one of the Most Influential Women Tax Attorneys in the United States. She is also a former John S. Nolan Fellow of the ABA Section of Taxation. Kelley is an adjunct professor at the Georgetown University Law Center where she teaches federal partnership tax, and is also on the faculty of the New York University Institute on Federal Tax Controversy and the Practising Law Institute’s faculty for the Federal Taxation of Corporations and Partnerships.