Terri has over 25 years experience in federal tax planning and controversy. Prior to entering private practice, Ms. Merriam was a Trial Attorney at the Office of Chief Counsel of the Internal Revenue Service for approximately 10 years where she was an experienced and successful litigator. At the Service, Terri was responsible for preparing all aspects of complex income tax cases for trial. This included first chair responsibilities in over 200 motion and trial proceedings.
While at the Office of Chief Counsel, Terri advised the Service on a variety of multi-million cases, including Puerto Rican tax credits, insurance, and accounting issues. While there, Terri developed a specialty in producer owned reinsurance companies advising agents across the nation about the issues. The expertise began with Wright v. Commissioner, T.C. Memo. 1993-328, aff'd 73 F.3d 372 (9th Cir. 1995), the case that set the precedence concerning acceptable practices in the producer owned reinsurance company industry. After Wright, Terri continued to advise and litigate producer insurance issues including Hinshaw's Inc. v. Commissioner, T.C. Memo. 1994-327, this concerned the timing when gross income from the sale of vehicle service contracts had to be taken into income and amortization of insurance payments.
Terri left the Office of Chief Counsel in 1997 and for the last 15 years, Terri has advised clients regarding international and insurance tax issues, focusing on issues concerning captive insurance and producer-owned insurance companies. She has successfully defended numerous producers and other parties to reinsurance transactions in IRS audits.
She is also a frequent lecturer on international and insurance tax issues. Terri's tax controversy practice includes representation at stages of the process, including during audit, appeal, investigation, collection, and litigation in Tax Court, District Court and the Appellate Courts.
