Zhanna Ziering

Practice Areas

Tax Litigation

Tax Controversy

Career

Zhanna A. Ziering, a tax controversy and litigation attorney, is the Managing Member of Ziering & Esman PLLC. Ms. Ziering represents individual and entity taxpayers in civil and criminal tax matters before taxing authorities and enforcement agencies, including the Internal Revenue Service, the Department of Justice, and state tax authorities. She has represented clients in federal and state courts, including the United States Tax Court and the Court of Federal Claims.

A zealous advocate for her clients, Ms. Ziering assists clients in all stages of the tax controversy and litigation cycle. She approaches each client with compassion and understanding and works collaboratively with the client to develop a strategy specifically tailored to the unique needs of each client.

Ms. Ziering is a well-regarded member of the tax law community, serving as the Chair of the Court Practice and Procedure Committee for the American Bar Association, Section of Taxation. She is a sought-after speaker and writer on topics related to tax controversy, tax litigation, and tax reporting compliance. She is the co-author of the original and new edition of Bloomberg BNA Tax Management Portfolio, “Report of Foreign Bank and Financial Accounts,” which is scheduled for publication in 2025. In addition, she was a co-author of the Center for Taxpayer Rights’ amicus curiae brief in the Supreme Court of the United States case Bittner v. United States, which was quoted in the Supreme Court’s opinion.

An avid supporter of the arts, Ms. Ziering provides pro bono tax representation to artists from a diverse range of industries, such as film, music, and fashion. She is also passionately committed to defending taxpayers facing penalties for international reporting noncompliance, frequently undertaking projects and cases on a pro bono basis advocating for a just and fair resolution.

Ms. Ziering lives in New Jersey with her husband, two rambunctious boys, and a Chocolate Labrador, named Mr. Chance Broadway. She is a native Russian speaker and insists on reading all the great Russian literature in its original language.

Professional Memberships

• Fellow, American College of Tax Counsel

• American Bar Association, Section of Taxation

• Current Vice-Chair of the Court Practice and Procedure Committee

• Former Vice-Chair of the Court Practice and Procedure Committee

• Former Co-Chair of Subcommittee on Offshore Enforcement for Civil and Criminal Tax Penalties Committee

• New York State Bar Association

• Federal Bar Association

Publications

• Zhanna Ziering and Aaron Esman pen American Bar Association Section of Taxation comments on proposed amendments to the Tax Court rules of practice and procedure, May 25, 2022.

• “Decrypting The New IRS Cryptocurrency Compliance Letters”, with Victor A. Jaramillo, Law360 Tax Authority, August 7, 2019

• “Deal or No Deal: The Unknown Cost of the IRS’s New Voluntary Disclosure Practice”, with Arielle Borsos, White Collar Crime Committee Newsletter, February 28, 2019

• “INSIGHT: Last call for OVDP: Use It or Lose It”, with Ben Eisenstat, Bloomberg Tax: Daily Tax Report, April 20, 2018

• “IRS Launches Issue Based Corporate Compliance Campaigns”, Global Tax Weekly, February 16, 2017

• Report of Foreign Bank and Financial Accounts (FBAR), (Book), Co-Author, Bloomberg BNA’s Tax Management Portfolio, June 29, 2016,

• “U.S. Offshore Account Enforcement Issues”, CCH’s Journal of Tax Practice & Procedure, September 30, 2014

• “The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court,” The Practical Tax Lawyer, December 1, 2012

• Comments to the Proposed Amendments to the Rules of the United States Tax Court, American Bar Association, March 7, 2011

• Comments to the Proposed Amendments to the Rules of the United States Tax Court, American Bar Association, May 27, 2009

• Selected Recent Developments in Administrative Practice, American Bar Association (May Meeting, Administrative Practice Committee), May 8, 2009