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Emily Parker represents taxpayers in IRS audits and appeals proceedings, state tax audits and hearings, and federal and state tax refund and deficiency litigation. She also advises on federal income tax and Texas tax planning, with expertise in taxation of natural resources and partnership and corporate transactions involving the petroleum industry. Emily has represented clients in a number of precedent-setting cases that decided important industry issues and developed previously unsettled issues of tax law.

Emily Parker is described by clients as “one of the best tax controversy lawyers in Texas” (2015) and hailed as a “terrific tax litigator who is practical, effective and can communicate with a broad range of people” (2011). – Chambers USA

Emily was previously 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 Matters

  • 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 deepwater offshore platforms
  • Representing an estate in an audit and Appeals proceeding relating to a claim for refund of over $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 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 Tax Court trial and Fifth Circuit appeal by the IRS relating to withholding on guarantee fees paid to its Mexican parent

Honors & Affiliations


  • Distinguished Service Award, ABA Section of Taxation, 2019
  • The Best Lawyers in America© by Woodward/White Inc. (Tax Law, Litigation & Controversy-Tax), 1983-2021
  • Chambers USA by Chambers and Partners (Tax: Controversy, Tax: Litigation), 2006-2021
  • Leading Lawyer, The Legal 500 US by Legalease (Tax Controversy, Tax: U.S. Taxes: Contentious), 2014-2017, 2019
  • Recognized Attorney, The Legal 500 United States by Legalease (Tax: Domestic Tax, Tax: Tax Controversy, Tax: U.S. Taxes: Contentious), 2015-2021
  • Most Influential Leaders in North Texas (Law: Managing Partners, Law: Tax), D CEO The Dallas 500, 2015, 2017, 2019
  • Dallas (Tax, Litigation & Controversy-Tax) Lawyer of the Year, The Best Lawyers in America© by Woodward/White Inc., 2010, 2012
  • Texas Super Lawyers® by Thomson Reuters (Tax), 2006-2020
  • Top 50 Female Attorneys in Texas, Texas Super Lawyers® by Thomson Reuters, 2008-2018
  • Top 100 Overall, Texas Super Lawyers® by Thomson Reuters, 2013-2014, 2017
  • Top 100 Dallas/Fort Worth Region, Texas Super Lawyers® by Thomson Reuters, 2008-2011, 2013-2014, 2017-2018
  • Outstanding Texas Tax Lawyer by the State Bar of Texas Tax Section, 2012
  • Best Lawyers in Dallas (Tax, Tax: Litigation), D Magazine, 2001, 2005, 2007-2008, 2011, 2013-2021
  • Tax Controversy Leaders 2015, International Tax Review
  • Top-Notch Lawyer (Tax Law), “Go-To Guide,” Texas Lawyer, 2007
  • Best Women Lawyers in Dallas, D Magazine, 2010
  • Best Personal Lawyers in Dallas (Tax), D Magazine, 2009
  • Best Business Lawyers in Dallas (Tax), D Magazine, 2009
  • Southern Methodist University (SMU) Dedman School of Law Distinguished Alumni for Government Service, 2007-2008
  • Who’s Who Legal: Texas (Corporate Tax), 2016-2017
  • Tax Controversy Leaders by International Tax Review, 2016


  • Fellow, American College of Tax Counsel
  • Member, American Bar Association; Section of Taxation, Chair, Natural Resources Committee, 1989-1991; Vice Chair, Appointments to Tax Court Committee, 2000-2001
  • Member, Dallas Bar Association; Chair, Tax Section, 1981-1982
  • Member, State Bar of Texas; Taxation Section, Council, 1985-1987; Chair, Natural Resources Committee, 1982-1983
  • Fellow, Dallas Bar Foundation, Texas and American Bar Foundation
  • Adjunct Instructor on Partnership Taxation, Southern Methodist University School of Law, 1984-1986
  • Chair, Southwestern Legal Foundation Institute on Oil & Gas Taxation, 1987-1989

Education & Admissions


  • J.D., 1973, with honors, SMU Dedman School of Law; Order of the Coif, The Barristers; Leading Articles Editor, Southwestern Law Journal
  • B.A., 1970, with highest honors, Stephen F. Austin State University; Alpha Chi scholastic honorary fraternity


  • Texas
  • Texas Supreme Ct.
  • U.S. Ct. of App., Federal Circuit
  • U.S. Ct. of App., Fifth Circuit
  • U.S. Ct. of App., Tenth Circuit
  • U.S. Ct. of App., Third Circuit
  • U.S. Ct. of Fed. Claims
  • U.S. Dist. Ct., N. Dist. Texas
  • U.S. Dist. Ct., S. Dist. Texas
  • U.S. Dist. Ct., W. Dist. Texas
  • U.S. Dist. Ct., Wyoming
  • U.S. Supreme Ct.
  • U.S. Tax Ct.

Related Team

Mary A. McNulty

Tax Controversies

Lee Meyercord

Tax Controversies

Abbey B. Garber

Tax Controversies