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Eleanor Moran McWaters

Counsel

Overview

Eleanor Moran McWaters advises clients on a variety of tax matters. She practices in the areas of tax controversy, litigation, and planning, with a specific focus on tax-exempt organizations.

Eleanor counsels a variety of tax-exempt organizations, including private foundations; supporting educational and religious organizations; and trade associations. She provides advice on compliance with the private foundation rules, including self-dealing and excess business holdings. Eleanor routinely advises tax-exempt organizations regarding exemption issues, joint ventures, public charity status, and the consequences of unrelated trade or business activities. 

Eleanor also represents clients involved in controversy with the IRS at all levels of the proceedings, including during examination, at appeals, and in litigation before the U.S. Tax Court, Court of Federal Claims, and U.S. district courts.

Career & Education

    • University of Virginia, B.A., 2013
    • University of Virginia School of Law, J.D., 2017
    • University of Virginia, B.A., 2013
    • University of Virginia School of Law, J.D., 2017
    • District of Columbia
    • Virginia
    • District of Columbia
    • Virginia

Eleanor's Insights

Client Alert | 3 min read | 10.10.25

New Post Appeals Mediation Pilot Program

On October 1, 2025, the IRS Independent Office of Appeals launched a two-year pilot program to make Post Appeals Mediation (PAM) more attractive and accessible to taxpayers. See IRS Announcement 2025-10. The new PAM pilot program offers taxpayers the opportunity to be assigned to a new Appeals team, which is otherwise unconnected to the underlying case, who will represent the original Appeals team in the mediation session. The assignment of the new Appeals team does not begin a new appeals process but rather is intended to help facilitate an expedited and impartial look at the underlying case with the goal of further exploring all potential paths to resolution prior to litigation....

Eleanor's Insights

Client Alert | 3 min read | 10.10.25

New Post Appeals Mediation Pilot Program

On October 1, 2025, the IRS Independent Office of Appeals launched a two-year pilot program to make Post Appeals Mediation (PAM) more attractive and accessible to taxpayers. See IRS Announcement 2025-10. The new PAM pilot program offers taxpayers the opportunity to be assigned to a new Appeals team, which is otherwise unconnected to the underlying case, who will represent the original Appeals team in the mediation session. The assignment of the new Appeals team does not begin a new appeals process but rather is intended to help facilitate an expedited and impartial look at the underlying case with the goal of further exploring all potential paths to resolution prior to litigation....