Overview

Emily Parker is a tax attorney in Holland & Knight's Dallas office. Ms. Parker represents taxpayers in Internal Revenue Service (IRS) audits and appeals proceedings, state tax audits and hearings, and federal and state tax refund and deficiency litigation.

In addition, Ms. Parker advises on federal income tax and Texas tax planning, with experience in taxation of natural resources and partnership and corporate transactions involving the petroleum industry. Ms. Parker has represented clients in a number of precedent-setting cases that decided important industry issues and developed previously unsettled issues of tax law.

Industry sources say:

She is a strong practical lawyer with broad experience, particularly on oil and gas taxation matters.

Chambers USA – America's Leading Lawyers for Business 2021 guide

Ms. Parker previously served as acting chief counsel and deputy chief counsel for the IRS. She is Board Certified in Tax Law by the Texas Board of Legal Specialization.

Representative Experience

  • Representing a publicly traded financial services company in an appeals proceeding relating to various tax advantaged transactions
  • Representing a publicly traded homebuilder in an appeals proceeding relating primarily to proposed disallowance of net operating loss carryovers
  • Representing a major petroleum company in an appeals proceeding relating to deduction of intangible drilling and development cost for deep water offshore platforms
  • Representing an estate in an audit and appeals proceeding relating to a claim for refund of more than $300 million in federal estate tax
  • Representing a major utility company in audit and appeals proceedings involving a variety of tax issues
  • Represented a sports franchise and owner in an IRS audit and appeals proceeding involving various issues, including issues unique to the sports business
  • Acted as an expert witness for a major investment banking firm regarding structure and effect of tax advantaged investments, and as an expert witness for a bankrupt company regarding a number of consolidated return related issues
  • Represented a publicly traded exploration and production company in an IRS audit and appeals proceeding regarding various issues, including tax treatment of a volumetric production payment
  • Represented a retailer in a U.S. Tax Court proceeding regarding arm's length pricing of insurance commissions received by the retailer in connection with customer insurance reinsured with a company owned by the retailer
  • Represented a U.S. corporation in a U.S. Tax Court trial and U.S. Court of Appeals for the Fifth Circuit appeal by the IRS relating to withholding on guarantee fees paid to its Mexican parent

Credentials

Education
  • Southern Methodist University Dedman School of Law, J.D., with honors
  • Stephen F. Austin State University, B.A., with highest honors
Bar Admissions/Licenses
  • Texas
Court Admissions
  • Texas Supreme Court
  • U.S. Court of Appeals for the Federal Circuit
  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Tenth Circuit
  • U.S. Court of Appeals for the Third Circuit
  • U.S. Court of Federal Claims
  • U.S. District Court for the Northern District of Texas
  • U.S. District Court for the Southern District of Texas
  • U.S. District Court for the Western District of Texas
  • U.S. District Court for the District of Wyoming
  • U.S. Supreme Court
  • U.S. Tax Court
Memberships
  • American College of Tax Counsel (ACTC), Fellow
  • American Bar Association, Section of Taxation, Natural Resources Committee, Chair, 1989-1991; Appointments to Tax Court Committee, Vice Chair, 2000-2001
  • Dallas Bar Association, Tax Section, Chair, 1981-1982
  • State Bar of Texas, Tax Section, Council, 1985-1987; Energy and Natural Resources Committee, Chair, 1982-1983
  • Dallas Bar Foundation, Texas and American Bar Foundation, Fellow
  • Southern Methodist University Dedman School of Law, Adjunct Instructor on Partnership Taxation, 1984-1986
  • Southwestern Legal Foundation, Institute on Oil and Gas Law and Taxation, Chair, 1987-1989
  • Leading Articles Editor, Southwestern Law Journal, 1973
Honors & Awards
  • The Best Lawyers in America guide, Litigation and Controversy-Tax, Tax Law, 1983-2022
  • Distinguished Service Award, American Bar Association (ABA) Section of Taxation, 2019
  • Chambers USA – America's Leading Business Lawyers guide, Tax: Controversy; Tax: Litigation, 2006-2021
  • The Legal 500 USA, Leading Lawyer, Tax Controversy, Tax: U.S. Taxes: Contentious, 2014-2017, 2019; Recognized Attorney, Tax: Domestic Tax; Tax: Tax Controversy; Tax: U.S. Taxes: Contentious, 2015-2021
  • Dallas 500, Most Influential Leaders in North Texas, D CEO magazine, Law: Managing Partners; Law: Tax, 2015, 2017, 2019
  • The Best Lawyers in America guide, Dallas Lawyer of the Year, Tax; Litigation and Controversy–Tax, 2010, 2012
  • Texas Super Lawyers magazine, Tax, 2006-2020
  • Top 50 Female Attorneys in Texas, Texas Super Lawyers magazine, 2008-2018
  • Top 100 Overall, Texas Super Lawyers magazine, 2013-2014, 2017
  • Top 100 Dallas/Fort Worth Region, Texas Super Lawyers magazine, 2008-2011, 2013-2014, 2017-2018
  • Outstanding Texas Tax Lawyer, State Bar of Texas, Tax Section, 2012
  • Best Lawyers in Dallas, D Magazine, Tax; Tax: Litigation, 2001, 2005, 2007-2008, 2011, 2013-2021
  • Tax Controversy Leaders, International Tax Review, 2015
  • Top-Notch Lawyer, "Go-To Guide," Texas Lawyer, Tax Law, 2007
  • Best Women Lawyers in Dallas, D Magazine, 2010
  • Best Personal Lawyers in Dallas, D Magazine, Tax, 2009
  • Best Business Lawyers in Dallas, D Magazine, Tax, 2009
  • Distinguished Alumni for Government Service, Southern Methodist University (SMU) Dedman School of Law, 2007-2008
  • Who's Who Legal: Texas (Corporate Tax), 2016-2017
  • Tax Controversy Leaders, International Tax Review, 2016
  • Order of the Coif

Publications

News