Kelley C. Miller Photo

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.


  • Georgetown University Law Center, 2006, LL.M., with distinction, Taxation, Senior Executive Editor, The Tax Lawyer; Co-winner, 2006 National LL.M. Law Student Tax Challenge Competition
  • Western New England College School of Law, 2005, J.D., cum laude, Dean's Award for Outstanding Law Graduate; The Honorable Robert S. Arnold Award (First Oralist, 2005 National First Amendment Moot Court Competition); National Association of Women Lawyers Award, President, Student Bar Association
  • University of San Francisco School of Law, 2004, Certificate in Trial Advocacy
  • Mount Holyoke College, 1994, B.A., cum laude

  • New Jersey
  • District of Columbia

  • U.S. Tax Court

  • District of Columbia Estate Planning Council
  • Member, 2020 Tax Authority Federal Advisory Board, Law360
  • Vice chair, Reed Smith Women’s Initiative Network (WINRS)
  • Adjunct professor of law, Georgetown University Law Center
  • Former adjunct professor of law, Temple University Beasley School of Law
  • Former adjunct professor of law, Western New England College School of Law
  • Faculty, Practising Law Institute
  • Lead Virginia, class of 2020
  • Women in Law Leadership Academy, class of 2019
  • Leadership Philadelphia, class of 2013
  • Board of directors, Center for Work Life Law at the University of California – Hastings School of Law
  • Board of directors, Philadelphia Tax Conference
  • Board of directors, Bloomberg BNA Advisory Committee on Passthrough Entities
  • Advisory board, Law360’s Federal Tax Authority
  • Past vice chair, ABA Young Lawyers Liaison to the Committee on Women in the Profession
  • Past vice chair, ABA Section on Taxation Young Lawyers Forum
  • Past chair, National Law Student Tax Challenge Competition, ABA Section on Taxation
  • Founder and past chair and co-chair, Tax Bridge to Practice Program, ABA Section on Taxation
  • Member, J. Edgar Murdock Inn of Court

Awards & Recognition

  • Selected among Virginia Business' "100 People to Meet in 2022: Go Getters."
  • Janet Spragens Pro Bono Award (2020)
  • Named one of Law360’s 14 Influential Women in Tax Law (2019). The Influential Women in Tax Law list is issued by Law360. A description of the selection methodology can be found at No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
  • Member of Law360’s Tax Group of the Year (2017). The Tax Group of the Year award is issued by Law360. A description of the selection methodology can be found at No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
  • Thompson Reuters Everyday Hero Award (2016). The Everyday Hero award is issued by Thomson Reuters. A description of the selection methodology can be found at No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
  • Named one of Pittsburgh’s Leading Ladies (2015)
  • John S. Nolan Fellow, ABA Taxation Section (2010–2011)

Notable Quotes

  • 8 January 2021 “Latest Virus Relief Provisions Add To State Tax Uncertainty” Law360
  • 3 April 2020 “Virus Poses Extra Obstacles for Attorneys With Tax Court Cases” Bloomberg Tax
  • 12 February 2018 "Chaos of Overturning Quill Could Spur Congressional Action" TaxNotes
  • 5 April 2016 "Tenth Circuit Refuses to Grant En Banc Review in DMA" TaxNotes
  • 17 November 2015 "News Analysis: What Do the IRS Partnership Audit Changes Mean for States?" TaxAnalysts TaxNotes
  • 12 August 2015 "Chicago Delays Lease Tax Implementation for Cloud Computing" TaxAnalysts 
  • 15 May 2015 "New York Provides Guidance on Cloud Computing Infrastructure as a Service" TaxAnalysts State Tax Today
  • 4 March 2015 "Kennedy's Concurrence in DMA Calls for Reconsiderations of QuillState Tax Today
  • 3 March 2015 “High Court Settles Only Part Of 'Amazon Tax' Debate” Law360
  • 15 August 2014 "New York Sales Tax on Software Guidelines Trying to 'Have It Both Ways'" Tax Analysts
  • 15 July 2014 "The Biggest Tax Cases of 2014: Midyear Report" Law360
  • 13 May 2014 "WorldCom High Court Bid Puts Data Taxation on the LineLaw360
  • 29 April 2014 "Oregon Tax Court Finds Rent-A-Center Not Unitary With Franchiser Subsidiary" Tax Analysts
  • 21 April 2014 "Tax Court Dulls Privilege Sword in Shelter FightsLaw360
  • 8 April 2014 "Democratic Nominee in D.C. Is a Mystery to Tax Community" Tax Analysts
  • 26 March 2014 "Netflix Streaming Suits Highlight Tax-Tech Mismatch" Tax Analysts