Theresa Abell has a BA from Golden Gate, JD from Univ. of Santa Clara, and an LLM in Taxation from NYU. Theresa has worked at the Internal Revenue Service ever since; first in Passthroughs & Special Industries. Now, she serves as the Special Counsel to the Associate Chief Counsel (Corporate), primarily working on regulations and other published guidance (mostly loss disallowance rules these past ten years or so.