FacultyFaculty/Author Profile

Theresa A. Abell

Internal Revenue Service
Senior Technician Reviewer (Corporate, Branch 1)
Accokeek, MD, USA

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 since 1983.  She began her career working on partnership issues, moving to Corporate in 1990.  First as a general attorney, then as a Special Counsel to the Associate Chief Counsel (Corporate), and now as a Senior Technician Reviewer.  Her work in Corporate has involved some litigation support, but has been primarily focused on regulations and other published guidance.  She was the principal drafter/reviewer on loss disallowance guidance beginning with the withdrawal of the Loss Disallowance Rule (former Treas. Reg. §1.1502-20) and ending with the issuance of the Unified Loss Rule (Treas. Reg. §1.1502-36), as well as the anti-loss importation rules (Treas. Reg. §1.362-3), the anti-loss duplication rules (Treas. Reg. §1.362-4), and the recent guidance applying section 382 to consolidated groups (Treas. Reg. §1.1502-91(g)(7)).  She also assisted in the development of numerous other guidance projects.

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