Profile

Adrian Ochoa is a tax controversy attorney who represents corporations, partnerships, and individuals in disputes with the Internal Revenue Service and state taxing authorities. His practice spans the full lifecycle of a tax dispute, from audit and administrative proceedings through litigation and collection. A native Spanish speaker who grew up in a border community, he regularly advises Spanish-speaking clients in complex federal tax matters, bringing both linguistic fluency and cultural understanding to high-stakes disputes.

His practice encompasses IRS examinations involving complex income tax issues, including partnership taxation, S corporations, pass-through entities, international tax, cross-border reporting obligations, employment tax, and penalty defense. He manages large-case examinations, responds to Information Document Requests, handles summons enforcement, and negotiates resolutions before the IRS Independent Office of Appeals. He also advises clients in collection proceedings, including collection due process hearings, installment agreements, offers in compromise, lien and levy disputes, trust fund recovery penalties, currently-not-collectible determinations, and passport revocation cases. In addition, Adrian advises businesses and closely held entities on state and local tax matters, including nexus analysis, multi-state compliance, entity structuring, and audit defense.

When administrative resolution is not achievable, Adrian litigates before the United States Tax Court, U.S. District Courts, and the U.S. Court of Federal Claims. His litigation experience includes deficiency cases, refund suits, innocent spouse claims, civil fraud and accuracy-related penalty disputes, and controversies involving foreign reporting obligations. He also advises on pre-controversy planning and compliance, including voluntary disclosures and offshore compliance matters such as FBAR and international information reporting. He additionally counsels nonprofit organizations on tax-exempt status, governance, and compliance, helping mission-driven organizations build sound structures from inception through growth.

Prior to private practice, Adrian clerked for the Honorable Juan F. Vasquez of the United States Tax Court, where he drafted judicial opinions, orders, and bench memoranda on a broad range of substantive and procedural tax issues — experience that directly informs how he builds factual records and approaches litigation strategy. He currently teaches Ethics at Trinity University and previously taught Tax Research at the University of the Incarnate Word.

Professional Affiliations

• American Bar Association, Tax Section
• San Antonio Bar Association
• Mexican American Bar Association of San Antonio

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