Michael R. Connelly

Mr. Connelly focuses his practice on federal tax controversy and litigation. Before joining the firm, he spent more than fourteen years with the IRS Office of Chief Counsel, where he represented the government in complex tax disputes before the U.S. Tax Court. His experience gives him a deep understanding of federal tax procedure, litigation strategy, and examination practices from the government’s perspective.

Mr. Connelly served as an attorney in the IRS Office of Chief Counsel from 2011 through 2026. In his most recent role, he handled U.S. Tax Court litigation, serving as lead trial counsel in significant, fact‑intensive cases. He tried multi‑day U.S. Tax Court trials in 2024 and 2026 and was responsible for all aspects of case development, including pretrial discovery, motion practice, trial presentation, and post‑trial briefing.

Earlier in his career, Mr. Connelly litigated Tax Court cases and advised IRS examination teams on a broad range of complex tax and procedural issues, including business deductions and credits, statutes of limitations, net operating losses, basis, administrative summons, and the negotiation and drafting of closing agreements.

Prior to that, Mr. Connelly practiced in the Tax Exempt and Government Entities (TEGE) division of Chief Counsel. In that role, he advised on matters involving exempt organizations, employment taxes, individual retirement accounts (IRAs), and qualified retirement plans, and provided legal guidance to IRS operating divisions on both technical and enforcement matters. He also litigated Tax Court cases involving those areas of law.

Throughout his tenure at the IRS, Mr. Connelly worked closely with revenue agents and IRS leadership, developing a comprehensive understanding of examination strategy, administrative procedure, and litigation risk.

Mr. Connelly was admitted to practice in Texas in 2011.