Michael Zima

Mike Zima is a Senior Manager in KPMG’s Tax Controversy Services (TCS) in the Southeast Region, with emphasis on Federal tax controversy and procedure.

Prior to joining KPMG in December 2013, Mike was a Senior Attorney with the Internal Revenue Service (IRS) Division Counsel for Large and Mid-Size Businesses in Jacksonville, Florida where he was responsible for the development and litigation of many high profile, complex tax cases. During his 20 year career with the IRS, Mike provided legal assistance to the Commissioner in all areas of federal tax controversy, including examinations, appeals, summons enforcement, collection actions, bankruptcy and criminal enforcement.

Mike has represented the Commissioner before the United States Tax Court in tax litigation involving large corporations. He also served as a Special United States Attorney representing the Commissioner’s interests before the United States Bankruptcy Court. As a Senior Attorney in the Office of Chief Counsel’s LB&I Division, Mike reviewed and assisted in the negotiation of advance pricing agreements, closing agreements and other dispute resolution procedures.  He also assisted agents in the LB&I Division with the conduct of examinations of large corporations (including some in the Commissioner’s Compliance Assurance Program (CAP)) and was the principal contact for agents conducting TEFRA examinations of passthrough entities. As a member of the Service’s Pharmaceutical Industry Issue Management Team, Mike assisted with development of issues and procedures unique to that industry.

As the advisor to revenue agents auditing corporate, partnership and individual returns, Mike wrote advisory opinions, drafted closing agreements (Form 906), and represented the Commissioner before the IRS Office of Appeals.  He gained specialized knowledge in multiple substantive federal tax issues, including TEFRA procedural issues, transfer pricing issues, the foreign tax credit, debt v. equity considerations, and the domestic production deduction (I.R.C. § 199).

At KPMG, Mike has represented multiple clients in IRS examinations, written letters seeking the abatement of tax penalties for reasonable cause under Treas. Reg. § 1.6038A-4(b)(1), I.R.C. § 6651(a)(1) and I.R.C. § 6651(a)(2), authored a technical memorandum evaluating a transaction’s qualification as a section 351 transaction, opened one Competent Authority case, initiated Taxpayer Advocate Office procedures and has represented one client before the IRS Appeals Division.

He holds a JD from Indiana University, and a BA from the University of Michigan Honors Program. He is also a member of the Florida Bar Association and the Indiana Bar Association.