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.