Principal Attorney

J.D., LL.M. in Taxation

Phone: 341.203.0280
Email: cece@codalawoffice.com

Ms. Zhang is a seasoned litigation attorney with over 10 years of experience, specializing in tax litigation against the IRS and the United States, as well as other complex civil matters. She has successfully represented individuals and businesses in California state courts, all districts of the U.S. District Court in California, the U.S. District Court in Colorado, the U.S. Tax Court, the U.S. Court of Federal Claims, and the Ninth Circuit Court of Appeals.

In addition to her litigation practice, Ms. Zhang provides expert advice on tax planning, estate planning, tax reporting, and international tax compliance.

Prior to starting her own firm, Ms. Zhang was an attorney at the San Francisco office of an international tax law firm. She represented high net-worth individuals and private businesses in all facets of tax controversy and litigation.

Representative Litigation Matters:

• Defended an $11 million tax collection suit in both the U.S. District Court (S.D. Cal) and the U.S. District Court, District of Colorado. The CFO of a corporation taxpayer failed to pay employment taxes for many years without disclosing the issue to the CEO and shareholders. The IRS assessed over $11 million in taxes and penalties against the corporation. The United States eventually agreed to settle the case for a significantly lower amount.

• Represented Debtor in a Chapter 7 bankruptcy proceeding against an IRS claim of over $8 million in income tax deficiency and civil fraud penalties.

• Wondries v. Comm’r., T.C. Memo. 2023-5 (U.S. Tax Court 2023). Successfully re-opened the previous trial and won the later trial. Completely defeated an IRS notice of deficiency in the amount over $500,000, potentially saving the taxpayer millions of dollars. The issue involved is whether a ranch operation of a major car dealership owner constituted a for-profit activity rather than a hobby.

• Defended a $5 million estate tax before the IRS Office of Appeals. The key issue involved whether private annuity contracts between family members should be characterized as a grantor trust, and whether any trust income should be taxable to the estate of the deceased taxpayer.

• Defended an IRS audit involving the potential taxation of billions of dollars in overseas assets by the U.S. Successfully defeated the IRS's attempt to access overseas assets by devising a tax strategy that removed the assets from the control of the audited taxpayer, and effectively thwarted enforcement of the IRS summons.

• Represented taxpayer in a $3 million tax refund suit involving abonnement loss and worthless securities deductions in California Superior Court and before the California Office of Tax Appeals.

• Represented an U.S. citizen in a civil law suit against the United States to secure the issuance a U.S. passport after unreasonable delays.

• Represented a California private religions foundation in an eminent domain dispute against the local county and city.

Admissions:

• State Bar of California

• The Ninth Circuit Court of Appeals

• U.S. Tax Court

• U.S. Court of Federal Claims

• U.S. District Court, Northern District of California

• U.S. District Court, Central District of California

• U.S. District Court, Eastern District of California

• U.S. District Court, Southern District of California

• U.S. District Court, District of Colorado

Education:

• Golden Gate University School of Law, LL.M in Taxation

• UC Davis, School of Law, J.D.

• Peking University, Bachelor of Laws