Heather L. Marello


Heather L. Schmidt


Ms. Marello is a Partner at Andreozzi Bluestein LLP.  Ms. Marello focuses her practice on tax controversy, representing clients before the Internal Revenue Service and New York State Department of Taxation and Finance from the initial audit through collection defense.  She has successfully resolved individual and corporate audits at exam, appeals, and Tax Court, has successfully resolved refund claims in the U.S. District Court.  In post-assessment cases, Ms. Marello has prevailed on innocent spouse claims and successfully negotiated Offers in Compromise.  In addition, Ms. Marello has assisted clients with voluntary disclosures of their offshore assets and facilitates mock permanent establishment audits for foreign corporations.

Prior to joining Andreozzi Bluestein LLP, Ms. Marello worked as an extern with IRS Office of Chief Counsel in Richmond, VA and aided in the representation of low income taxpayers through William and Mary’s Federal Tax Clinic. Ms. Marello continues demonstrating her dedication to the community through her pro bono work with the Erie County Bar Association’s Volunteer Lawyer’s Project.  In addition, Ms. Marello has served as an assistant adjunct teaching tax controversy at the University at Buffalo School of Law and teaching business law at Canisius College.


  • New York
  • Tax Court
  • Western District of New York
  • U.S. District Court for the District of Puerto Rico
  • U.S. Court of Appeals for the Eighth Circuit
  • Notary Public

Academic Degrees

  • J.D., cum laude, The College of William and Mary School of Law
  • B.A., summa cum laude, State University of New York at Buffalo

Professional Affiliations

  • Member, Erie County Bar Association
  • Member, American Bar Association

Speaking & Publications

  • “But It’s Not My Fault” How to Obtain Innocent Spouse Relief (Mar. 1, 2019)
  • Understanding Audit, Issues and Strategies (Part 2) (Nov. 13, 2018)
  • Speaker, Federal and State Tax Controversy Update 65th Tax Institute (Buffalo, NY Nov. 2018)
  • Restricting Travel to Compel Payment of Delinquent Tax Debts (Buffalo Law Journal, Oct. 2018)
  • FBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness (Buffalo Law Journal, Jan, 2018)
  • IRS Relaxes Bona Fide Residency Rules in the Wake of Hurricanes Irma and Maria (Oct. 5, 2017)
  • Law Creates New Due Dates for FBAR and Other Tax and Informational Returns (Aug. 3, 2015)
  • Taxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report (Jan. 16, 2015)
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