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Case Western Reserve University, B.A., summa cum laude

The University of Chicago, The Law School, J.D. with honors

Open focuses her practice on State and Local Taxation.  Her extensive experience includes representation of taxpayers in administrative and court appeals in New Jersey, New York and Illinois on a variety of complex issues, including apportionment of business income, combined reporting, constitutional nexus, the Internet Tax Freedom Act, nonresident and resident personal income taxation, sales and use taxation, and the imposition of various industry specific taxes, including telecommunications, utilities, and amusement taxes.  

Open has represented both public and private companies engaged in a wide range of activities, including manufacturing, retail, telecommunications, banking, transportation, construction, sports, television and radio production, publishing, and insurance.  She has also represented individuals challenging residency determinations and assessments arising from adjustments to income and credits.

In addition to a wealth of experience at conducting discovery, witness selection and preparation, motion practice, brief writing, trials and appeals, Open is experienced and adept at identifying efficient and practical pre-decision settlement strategies to resolve tax controversies.

Open is a frequent author of articles on tax topics in State Tax Notes, Bloomberg Tax and Law360, and has spoken on state and local tax issues before such groups as the Tax Executives Institute, the American Bar Association, the Council on State Taxation, and the Georgetown University Law Center Advanced State and Local Tax Institute. 

Prior to joining Hodgson Russ Open was counsel with a multistate tax practice located in New York City.


  • Listed, Best Lawyers in America Ones to Watch, (Tax Law) 2022

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Professional Associations

  • American Bar Association
  • New Jersey State Bar Association
  • New York State Bar Association
  • New York City Bar Association
  • New York City Bar SALT Committee