IRS Representation Conference [2-Day Event]

Frank Agostino, Esq
Barry Fischman, CPA
Laura L. Gavioli, Esq
Eric L. Green
Barbara Kaplan, Esq
Anastasia King
Walter Pagano
Lisa E. Perkins, Esq
Jeffrey M. Sklarz, Esq
Sara V. Spodick, Esq
Zhanna Ziering, Esq
William Bogardus
Sandford J. Boxermann, Esq
Caroline D. Ciraolo, Esq
Amalia C. Colbert
Erin M. Collins
Amanda Evans
Miri Forster
G. Michelle Ferreira, Esq
Sanessa S. Griffiths, Esq
Karen L. Hawkins, Esq
Steven I. Hurok, Esq., CPA
Victor A. Jaramillo, Esq
Stuart Katz, Esq
Andrew Keyso
Michele A. Lazzara, CPA, CGMA, CBIZ
Honorable Diana Leyden
Kristin M. Lynn, Esq
Jason A. Marsh, Esq
Daniel Mayo, JD, LL.M.
Guinevere M. Moore, Esq
Roger Nemeth, EA
Fran Obeid, Esq
Nina Olson
Damon Rowe, Esq
Lawrence A. Sannicandro
Michael Sardar, Esq
Jeffrey M. Sklarz, Esq
Richard Tierney
J. Robert Turnipseed, Esq
Michael A. Villa Jr., Esq
Anthony F. Vitiello, Esq
Philip J. Wilson, CPA
Beverly Winstead, Esq
Caren Zahn, EA
Margaret Romaniello
Joseph McCarthy|
Paul Greenberg, CPA
Richard J. Sapinski
Kristy Moquin
Robert M. Finkel
Jason Freeman
Frank Agostino, Esq | Agostino & Associates, P.C.
Barry Fischman, CPA | Marcum LLP
Laura L. Gavioli, Esq | Alston & Bird
Eric L. Green | Green & Sklarz LLC
Barbara Kaplan, Esq | Greenberg Traurig
Anastasia King | Asst. United States Attorney, District of Connecticut
Walter Pagano | Eisner Advisory Group
Lisa E. Perkins, Esq | Green & Sklarz
Jeffrey M. Sklarz, Esq | Green & Sklarz
Sara V. Spodick, Esq | Director, Low Income Taxpayer Clinic, Quinnipiac Law School
Zhanna Ziering, Esq | Moore Tax Law Group LLC
William Bogardus | Office of Chief Counsel, IRS
Sandford J. Boxermann, Esq | Capes, Sokol, Goodman & Sarachan, PC
Caroline D. Ciraolo, Esq | Kostelanetz & Fink, LLP
Amalia C. Colbert | SB/SE Commissioner, IRS
Erin M. Collins | National Taxpayer Advocate
Amanda Evans | Green & Sklarz, LLC
Miri Forster | Eisner Advisory Group LLC
G. Michelle Ferreira, Esq | Greenberg Traurig, LLP
Sanessa S. Griffiths, Esq | Skadden, Arps, Slate, Meagher & Flom, LLP
Karen L. Hawkins, Esq | Yachats
Steven I. Hurok, Esq., CPA | Citrin Cooperman
Victor A. Jaramillo, Esq | Caplin & Drysdale
Stuart Katz, Esq | Cohen & Wolf, PC
Andrew Keyso | Chief, Independent Office of Appeals, IRS
Michele A. Lazzara, CPA, CGMA, CBIZ | Marks Paneth
Honorable Diana Leyden | US Tax Court
Kristin M. Lynn, Esq | Green & Sklarz, LLC
Jason A. Marsh, Esq | Green & Sklarz
Daniel Mayo, JD, LL.M. | Withum
Guinevere M. Moore, Esq | Moore Tax Law Group
Roger Nemeth, EA | Tax Help Software
Fran Obeid, Esq | MFO Law PC
Nina Olson | Center for Taxpayer Rights
Damon Rowe, Esq | Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
Lawrence A. Sannicandro | McCarter & English, LLP
Michael Sardar, Esq | Kostelanetz & Fink
Jeffrey M. Sklarz, Esq | Green & Sklarz
Richard Tierney | Deputy Director of Exam, IRS
J. Robert Turnipseed, Esq | Ambrecht Jackson, LLP
Michael A. Villa Jr., Esq | Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
Anthony F. Vitiello, Esq | Connell Foley
Philip J. Wilson, CPA | Marcum
Beverly Winstead, Esq | Low Income Taxpayer Clinic, University of Maryland School of Law and Law Offices of Beverly Winstead, PC
Caren Zahn, EA | Agostino & Associates
Margaret Romaniello | Senior Stakeholder Liaison, IRS
Joseph McCarthy| | Senior Stakeholder Liaison, IRS
Paul Greenberg, CPA | Ritch, Greenberg & Hassan
Richard J. Sapinski | Sills Cummis & Gross P.C.
Kristy Moquin | Deputy National Taxpayer Advocate, IRS
Robert M. Finkel | Moritt Hock & Hamroff LLP
Jason Freeman | Freeman Law
On-Demand: November 17 - 18, 2022
IRS Representation Conference [2-Day Event]

$245.00 11 hour CLE

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Program Summary

This comprehensive, full-day event features panels with private practitioners and government employees from the Internal Revenue Service and Department of Justice Tax Division covering a myriad of hot topics that practitioners need to be familiar with when representing clients before the IRS. The focus is on the practical issues and how to handle them rather than theoretical issues.

Key topics to be discussed:

  • Straight Talk on Security Six: What Every Tax Pro Must Consider
  • The IRS Exam: Who Should Deal with the Revenue Agent?
  • Challenging Tax Penalties
  • US Tax Court: Considering Supervisory Approval and Reasonable Cause
  • IRS Update
  • Enforcement Trends: Crypto, Conservation Easements, Micro-captives, Marijuana – What’s Hot and What’s Not!
  • Ethics: The Ethical Issues Around Whistleblowing: Can We, or Can’t We?
  • Track A: The Tax and Non-Tax Pitfalls of Liquidating the Business
  • Track B: Estate & Gift Update Part 1: IRS Challenges to Your Client’s Best-Laid Plans
  • Track A: From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime
  • Track B: Estate & Gift Update Part 2: Pitfalls When Handling the Estate and Why the Tax Returns Matter!
  • Track A: Representing Clients Before a Resource-Challenged IRS
  • Track B: Defending You! Preparer Penalties and Referrals to the OPR
  • Track A: Confessions of a Tax Evader: Resolving Criminal Tax Cases with Guilty Pleas
  • Track B: Gotcha! Challenging Tax Penalties on International Forms

Date: November 17-18, 2022

Closed-captioning available

Speakers

Frank-Agostino_Agostino-&-Associates_myLawCLEAgostino, Esq | Agostino & Associates, P.C.

Frank Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, Mr. Agostino was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. He also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, Mr. Agostino taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. He also served as the co-director of the Rutgers Federal Tax Law Clinic.

Mr. Agostino is a frequent speaker and author on tax controversy and litigation matters. He serves on the Advisory Board of the Journal of Tax Practice and Procedure. Mr. Agostino is actively involved with the American Bar Association and the New York County Lawyers’ Association. Mr. Agostino is also the President of Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area.

 

Barry-Fischman,-CPA_Marcum-LLP._myLawCLEFischman, CPA | Marcum LLP

Barry A. Fischman is a partner in the Firm’s New Haven, Connecticut office and a member of its National Construction, Real Estate, Business Enterprise Tax Services, High-Net-Worth Individuals, Tax Compliance, Family Wealth Services, and Trusts and Estates practice groups. He has more than 35 years of tax and consulting experience providing services primarily to closely-held businesses. He has a wide range of industry experience including construction, real estate, research and development, professional services, manufacturing and high-net-worth individuals.

Mr. Fischman represents clients before the Internal Revenue Service and the Connecticut Department of Revenue Services. A frequent speaker, Mr. Fischman is often asked to present on topics regarding income taxation matters for construction companies; research and development credit opportunities; and gift, estate and asset protection planning.

 

Laura-L.-Gavioli,-Esq._Alston-&-Bird_myLawCLELaura L. Gavioli, Esq | Alston & Bird

Laura L. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, Laura is known for achieving practical, client-driven goals when defending against IRS inquiries. She has represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the U.S. and advises clients on the IRS Whistleblower Program. She attained taxpayer victories in civil tax cases in U.S. Tax Court and federal district courts, eliminating IRS penalties.

Laura focuses her practice on the business dealings and asset holdings of U.S. taxpayers abroad. She has extensive knowledge of the IRS’s international exchange-of-information techniques, including treaty requests and other methods of cross-border cooperation among taxing authorities.

Laura has an aptitude for clearly explaining highly technical, complex tax issues. She has litigated numerous cases addressing jurisdictional questions under taxation statutes and setting precedent for statutes of limitations. Laura also advocated for multinational enterprises, relying on plain-language readings of taxation statutes to combat unjustified IRS positions, including those taken in regulations under the Tax Cuts and Jobs Act.

 

Eric-L.-Green_Green-&-Sklarz-LLC_myLawCLEEric L. Green | Green & Sklarz LLC

The focus of Attorney Eric L. Green’s practice is taxpayer representation before the IRS, Department of Justice Tax Division and state departments of revenue. He is a frequent lecturer on tax topics, including handling tax audits and tax controversies. Eric also has the weekly Tax Rep Network podcast, which can be found in Apple Podcasts, ITunes, Spotify and all other podcasting platforms. He is the author of The Accountant’s Guide to IRS Collection and The Accountant’s Guide to Resolving Tax Debts: Offers-in-Compromise, Installment Agreements & Uncollectable Status.

Eric is the creator, author and lecturer for the IRS Representation Certificate Program with the University of Connecticut Business School which trains tax professionals to properly represent taxpayers before the IRS. He is a frequent lecturer for national groups, including the AICPA, NATP, ABA and CCH. Mr. Green has been quoted in CNN, the Wall Street Journal, The Street, USA Today, Consumer Reports – Finance, among other media sources, and has served as a columnist for CCH’s Journal of Tax Practice & Procedure.

Eric founded Tax Rep Network, which is an online membership group that trains and supports tax professionals building their IRS Representation practices, and he founded The New England IRS Representation Conference, which is one of the largest tax conferences in the country focused on IRS Representation and controversy hot topics. Eric is also the creator of the Tax Rep App to assist tax professionals in automating their marketing efforts.

Eric developed a national reputation by building a remarkable record of negotiating favorable settlements in thousands of civil cases against government agencies and has also been able to convince government agents and attorneys to forgo criminal charges and civilly resolve many cases. Eric was recognized as a “Connecticut Super Lawyer” in the field of taxation.

Attorney Green has served as adjunct faculty at the University of Connecticut School of Law where he taught law students to handle taxpayer representation matters in the low income taxpayer clinic. Prior to practicing law, Eric served as a senior tax consultant for national and international accounting firms, including KPMG and Deloitte & Touche.

Attorney Green’s commitment to professional excellence is demonstrated by his involvement in numerous professional organizations. He is a past Chair of the American Bar Association’s Closely Held Businesses Committee, and has served as the chairman of the subcommittees on Business Succession Planning and Estate Planning. Attorney Green is a past Chair of the Connecticut Bar Association’s Tax Section and is a Member of its Estate & Probate Section.

Eric is a Fellow of the American College of Tax Counsel, an organization in which membership is an honor reserved for those at the top of their chosen profession. The College’s members, called “Fellows,” are recognized for their extraordinary accomplishments and professional achievements and for their dedication to improving the practice of tax law. Fellows must be nominated by their peers for this honor. Self-nomination is not permitted. Each nominee must satisfy the established criteria and pass a rigorous screening process before he or she becomes a Fellow.

Attorney Green is admitted to practice in New York, Connecticut and Massachusetts and is a member of the United States Tax Court Bar. Attorney Green is also a member of the Connecticut and Massachusetts Bar Associations, as well as the American Bar Association. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honors graduate from New England School of Law. He earned a Masters of Laws in Taxation from Boston University School of Law.

 

Barbara-T.-Kaplan_Greenbergtraurig_myLawCLEBarbara Kaplan, Esq | Greenberg Traurig, LLP

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

 

Anastasia-King_Asst.-United-States-Attorney,-District-of-Connecticut_myLawCLEAnastasia King | Asst. United States Attorney, District of Connecticut

 

 

 

Walter-Pagano_Eisner-Advisory-Group-LLC_myLawCLEWalter Pagano | Eisner Advisory Group LLC

Walter Pagano is a Tax Partner with more than 35 years of diversified and relevant litigation consulting and forensic accounting experience. He has testified in federal and state courts, as well as at arbitration hearings, and has served as a federal, state, and bankruptcy court appointed forensic accountant and special fiscal agent. Walter’s experience, knowledge, and expertise enable practicing attorneys and corporate counsel to rely on his objective and independent critical thinking and judgment as a source to ascertain the financial facts in a wide variety of civil and criminal cases that have included white collar crime, internal investigations, adequacy of internal controls, commercial disputes, civil and criminal tax controversy, internal and external fraud schemes, financial statement fraud, shareholder and matrimonial disputes, guardianship litigation, accounting malpractice and third-party asset misappropriation.

Walter has served as an expert witness in diverse cases such as IRS practice and procedure, breach of accounting and tax representations and warranties, damage calculations, criminal tax prosecutions, and guardianship accounting.

Prior to joining the firm, Walter served as Partner-in-Charge of Litigation Consulting and Forensic Accounting at another public accounting firm. His background also includes serving 10 years as a revenue agent with the United States Treasury Department, Internal Revenue Service (IRS). In this position, Walter conducted forensic and tax audits of businesses and individuals, and also trained revenue agents and criminal investigation special agents in the applicable provisions of income tax law. In addition, he was an appeals officer, co-authored the IRS’ Commodity Tax Shelter Training Manual, examined abusive tax shelters, and assisted federal prosecutors as a forensic accountant in prosecuting various tax crimes.

Walter is a frequent guest speaker on topics such as forensic accounting, IRS investigations and white collar crime.

 

Lisa-E.-Perkins,-Esq._Green-&-Sklarz,-LLC_myLawCLELisa E. Perkins, Esq | Green & Sklarz, LLC

Lisa Perkins joined Green & Sklarz after more than 17 years with the U.S. Department of Justice. She worked for five years as a trial attorney in the Western Criminal Enforcement Section of the Tax Division, prosecuting tax crimes in the western half of the United States, then moved to Connecticut. Until January 2015, she was an Assistant U.S. Attorney in Hartford, handling both civil and criminal litigation in federal court on behalf of the U.S. government. Her caseload included tax and financial crimes, immigration, employment discrimination, medical malpractice, Freedom of Information Act litigation and civil rights cases. Attorney Perkins is also an Assistant Clinical Professor and Associate Director of the Tax Clinic at UConn School of Law, where she supervises law students who represent low-income taxpayers before the IRS and in Tax Court.

Attorney Perkins has established a record of convincing government agents and attorneys to forgo criminal charges and civilly resolve many cases. In those cases where it was necessary for clients to either go to trial or plead guilty, Lisa has an exceptional track record of obtaining below guidelines sentences for clients.

Lisa is a Fellow of the American College of Tax Counsel, an organization in which membership is an honor reserved for those at the top of their chosen profession. The College’s members, called “Fellows,” are recognized for their extraordinary accomplishments and professional achievements and for their dedication to improving the practice of tax law. Fellows must be nominated by their peers for this honor. Self-nomination is not permitted. Each nominee must satisfy the established criteria and pass a rigorous screening process before he or she becomes a Fellow.

Attorney Perkins earned a bachelor’s degree from Michigan State University, a Juris Doctor from Michigan State University College of Law and an LL.M. in Taxation from Georgetown Law.

 

Jeffrey-M.-Sklarz,-Esq._Green-&-Sklarz,-LLC_myLawCLEJeffrey M. Sklarz, Esq | Green & Sklarz, LLC

Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs including: bankruptcy/bankruptcy litigation, creditor/debtor litigation, tax litigation, and commercial litigation. He regularly tries cases and appeals before Connecticut’s state and federal courts. Jeff has particular experience regarding the interplay between bankruptcy and tax law.

Jeffrey M. Sklarz was named the Best Lawyers® 2022 Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law “Lawyer of the Year” in New Haven and was included in the 2021 Edition of The Best Lawyers in America© for Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law. He is a Fellow of the American College of Tax Counsel (ACTC). Jeff is a 2005 recipient of the Connecticut Law Tribune’s New Leaders of the Law Award (Overall Achievement, Fairfield County) and has been listed by New England Super Lawyer® as a Super Lawyer (Business Litigation) since 2010 (Rising Star 2010-2013) and was named a Fellow of the American Bar Association, Business Law Section (2011 – 2013).

Jeff received his B.A. in government from Colby College, his J.D. from the University of Connecticut, School of Law, and his LL.M. (Taxation) from Boston University, Graduate Tax Program.

Jeff holds (and has held) many positions with local and national bar organizations and is a frequent writer and lecturer on topics involving bankruptcy, tax litigation and commercial litigation. Current positions include: Chair of the Bankruptcy Study and Reform Committee of the American Bar Association, Business Law Section, and Program Director for the American Bar Association, Business Law Section, Business Bankruptcy Committee. Jeff is also currently President of the New Haven Jewish Community Center.

Jeff is frequent lecturer and writer on topics involving bankruptcy and tax. He is also the co-founder of the New England IRS Representation Conference.

 

Sara-V.-Spodick,-Esq._Director,-Low-Income-Taxpayer-Clinic,-Quinnipiac-Law-School_myLawCLESara V. Spodick, Esq | Director, Low Income Taxpayer Clinic, Quinnipiac Law School

Education

BA, Southern Connecticut State University
JD, Quinnipiac University

Courses
LAWS 295 Tax Clinic
Law Fall 2022
LAWS 612 Advanced Tax Clinic
Law Fall 2022
LAWS 694 Tax Clinic Seminar
Law Fall 2022

 

Zhanna A. Ziering, Esq_Moore Tax Law Group_myLawCLEZhanna Ziering, Esq | Moore Tax Law Group LLC

Zhanna A. Ziering, a tax controversy and litigation attorney, is a Member in the Firm’s New York office. Ms. Ziering’s practice focuses on representing individual and entity clients in civil and criminal tax disputes with federal and state governments as well as in regulatory proceedings. She defends both individual and entity taxpayers before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators. Ms. Ziering advises taxpayers in connection with various tax issue, including those arising in connection with domestic and offshore income and assets, cryptocurrency, and U.S. tax and regulatory reporting requirements.

She approaches each of her client engagements with empathy and kindness and develops a strategy for dispute resolution by taking the client’s views, needs, and resources into consideration. When faced with alternatives for dispute resolution, Ms. Ziering discusses the various available options, and the benefits and drawbacks of each such option, with the clients and works together with them to develop the approach tailored to that particular client and situation.

Ms. Ziering strives to resolve every tax dispute that her clients are facing amicably and efficiently while zealously advocating on her clients’ behalf. Her significant experience in representing clients in various stages of a tax dispute allows her to aptly navigate the procedural hurdles and achieve best results possible under the circumstances for each client. A well-regarded member of the legal community, Ms. Ziering is actively engaged in American Bar Association, Section of Taxation. She currently serves as the Vice Chair of Court Practice and Procedure Committee.

Ms. Ziering is also a sought-after speaker and writer on various topics relating to tax controversy and litigation. She is a co-author of the Bloomberg BNA’s Tax Management Portfolio, Report of Foreign Bank and Financial Accounts. An avid supporter of the arts, Ms. Ziering had offered pro bono tax representation to artists from a diverse range of industries, such as film, music, and fashion. She also provided counsel to low-income taxpayers with a broad range of tax issues through Duke University School of Law’s Low-Income Taxpayer Clinic and New York University School of Law’s Tax Clinic. Ms. Ziering lives in New Jersey with her husband, two rambunctious boys, and a Chocolate Labrador, named Mr. Chance Broadway. Ms. Ziering is a native Russian speaker and insists on reading all the great Russian literature in its original language.

 

Kristen-Rico_Maria-Papageorgiou_myLawCLEWilliam Bogardus | Office of Chief Counsel, IRS

 

 

 

Sandford-J.-Boxermann,-Esq_Capes,-Sokol,-Goodman-&-Sarachan,-PC_myLawCLESandford J. Boxermann, Esq | Capes, Sokol, Goodman & Sarachan, PC

Sandy defends individuals and corporations in white collar investigations and prosecutions. He also represents taxpayers in civil and criminal tax matters.
Sandy has experience in both the public and private sectors. From 1991 to 1994, he served as assistant public defender in the City of St. Louis, where he gained valuable experience as first chair in numerous jury and bench trials. From 1988 to 1991, and from 1994 through the present, he has worked in private law firms. Sandy was one of the founders of Capes Sokol in 2001.

 

Caroline-D.-Ciraolo_Kostelanetz-&-Fink_myLawCLECaroline D. Ciraolo, Esq | Kostelanetz & Fink, LLP

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and administrative tax tribunals, providing related tax advice, conducting internal investigations, consideration of domestic and foreign compliance options including voluntary disclosures, and representing individuals and institutions in criminal tax investigations and prosecutions.

 

Kristen-Rico_Maria-Papageorgiou_myLawCLEAmalia C. Colbert | SB/SE Commissioner, IRS

 

 

 

Erin-M.-Collins_National-Taxpayer-Advocate_myLawCLEErin M. Collins | National Taxpayer Advocate

Erin Collins is the “voice of the taxpayer” within the IRS and before Congress. Under her leadership, the Taxpayer Advocate Service (TAS), an independent organization within the IRS, helps taxpayers resolve their IRS account issues, advocates on behalf of taxpayers, and works towards systemic change to mitigate taxpayer problems. She joined the Taxpayer Advocate Service in March 2020 to advocate for taxpayers, protect their rights, and work toward improving the quality of taxpayer service and tax administration.

Erin has more than 35 years of experience in tax law, spanning 15 years in the IRS Office of Chief Counsel and 20 years at the accounting firm of KPMG LLP, where she retired in 2019 as the Tax Managing Director in charge of its tax controversy practice for the Western region. As a Special Trial Attorney for the IRS, she was responsible for the development and litigation of high-profile, complex tax cases.

Erin was the Industry Counsel for Savings and Loans during the time of the S&L crisis. Over a six-year period, she worked very closely with the Treasury Department, the Commissioner, the Office of Chief Counsel, the Federal Deposit Insurance Corporation and Resolution Trust Corporation. In both 1995 and 1997, she received Chief Counsel’s highest award, the National Litigation Award. In 1993, she received the Western Region’s highest Litigation Award for her outstanding achievements.

At KPMG, Erin represented thousands of individuals, partnerships, small companies, and corporate taxpayers on technical and procedural tax matters. She represented clients in federal examinations and IRS appeals on domestic and international tax issues, including transfer pricing disputes, foreign tax credits, research and experimentation credit claims, net operating loss utilization calculations, restructurings, treaty interpretations, executive compensation, and application of accounting methods. She also has represented several clients before the U.S. Tax Court.

Erin was the co-author of the Practising Law Institute’s IRS Practice and Procedure Deskbook and has spoken frequently on IRS practice, procedure, controversy, and litigation matters before many professional organizations. Before joining TAS, she represented a number of clients pro bono to help them resolve issues with the IRS. She was also a volunteer and board member of a non-profit organization, Step Up, whose mission was to help girls in under-resourced communities to fulfill their potential by empowering them to become confident, college-bound, career-focused, and ready to join the next generation of professional women.

 

Amanda-Evans_Green-&-Sklarz,-LLC_myLawCLEAmanda Evans | Green & Sklarz, LLC

Amanda is an enrolled agent (E.A) and paralegal with Green & Sklarz LLC. As an E.A., Amanda is a federally-authorized tax practitioner who has technical expertise in the field of taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all administrative levels—examination, collection, and appeals—of the Internal Revenue Service.

Amanda assists in both the tax representation and bankruptcy practice groups at the firm.

Amanda brings nearly 8 years of experience working for the Connecticut Bar Association (CBA) where she coordinated educational seminars for attorneys throughout Connecticut. She also managed the CBA’s attorney board certification program.

Amanda is the current Secretary of the Connecticut Society of Enrolled Agents and an associate member of the Connecticut Bar Association. She was a presenter at the 2016 New England IRS Representation Conference on issues surrounding representation of an innocent spouse and the 2017 New England IRS Representation Conference on IRS Offers-in-Compromise. In 2019, she presented at the New England IRS Representation Conference on Offers & Installment Agreements and focused her discussion on how to handle business assets. Amanda has also given presentations on hobby loss exams, IRS collection, tax liens and tax levies.

She is a 2006 graduate of Trinity College in Hartford and a current resident of Wolcott. In her spare time, she teaches group fitness classes at her local gym.

 

Miri Forster_myLawCLEMiri Forster | Eisner Advisory Group LLC

Miri Forster is a Partner and National Leader of the Tax Controversy practice, specializing in providing tax dispute resolution services to public and private corporations, partnerships and high net worth individuals on a wide range of technical and procedural issues. She has over 20 years of IRS practice, procedure, and tax controversy experience.

Miri represents businesses and individuals before the IRS Examination and Appeals Divisions on complex domestic and international tax issues. She also obtains private letter rulings from the IRS National Office, including 9100 relief requests for missed elections. Miri assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors, obtains penalty abatements and refunds, resolves IRS account issues, and advises on a broad range of IRS practice, procedure and dispute resolution matters.

Prior to joining the firm, Miri was a Tax Controversy Principal at a Big 4 firm. Miri also previously served as an Attorney-Advisor at the United States Tax Court in Washington, D.C., and is an attorney licensed in the states of New York and New Jersey as well as Washington, D.C.

Miri was named a 2022 honoree of the Executive Women of New Jersey’s Policy Makers. She also serves as Co-chair of Women of EisnerAmper, New Jersey Chapter.
Miri is a frequent speaker on IRS enforcement trends, the centralized partnership audit regime and its impact on pass-through entities and investors, voluntary disclosures of inadvertent tax compliance matters and related penalties, and other IRS practice, procedure and dispute resolution topics.

 

G.-Michelle-Ferreira,-Esq._Greenberg-Traurig,-LLP_myLawCLEG. Michelle Ferreira, Esq | Greenberg Traurig, LLP

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco office and Co-Managing Shareholder of the Silicon Valley office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards.

As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.

Michelle has 21 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.

 

Sanessa-S.-Griffiths,-Esq._Skadden,-Arps,-Slate,-Meagher-&-Flom,-LLP_myLawCLESanessa S. Griffiths, Esq | Skadden, Arps, Slate, Meagher & Flom, LLP

Sanessa Griffiths advises clients on a broad range of tax controversy matters and transactional situations.

Ms. Griffiths’ practice focuses on matters related to high-stakes and complex tax controversies involving transfer pricing, economic substance and business purpose doctrines, and tax treaty interpretation. With experience representing large U.S. and multinational companies at the audit, administrative proceeding and litigation phases, she routinely performs fact-finding and analysis in connection with multilayered tax matters, and assists clients in navigating legal and practical considerations of prelitigation and litigation work.

Ms. Griffiths is very active in Skadden’s diversity, equity and inclusion initiatives, particularly regarding the hiring and retention of attorneys of color. She is a member of the ABA steering committee that established the Loretta Collins Argrett Fellowship, which is focused on creating a more diverse, equitable and inclusive ABA Tax Section and tax bar. She also has been involved in several pro bono matters, including drafting amici briefs for the U.S. Supreme Court, advising on federal and state tax exemptions for nonprofit organizations and representing asylum seekers.

 

Karen-Hawkins_Yachats,-Ore_myLawCLEKaren L. Hawkins, Esq | Yachats

After serving six years as the Director of the Office of Professional Responsibility for the Internal Revenue Service where she oversaw the standards of conduct for Attorneys, CPA’s, Enrolled Agents, Enrolled Retirement Plan agents, Actuaries, Appraisers and Unlicensed Return Preparers who “practice” before the Internal Revenue Service pursuant to Treasury Circular 230, Ms. Hawkins left government to reenter legal practice.

 

Steven-I.-Hurok,-Esq.,-CPA_Citrin-Cooperman_myLawCLESteven I. Hurok, Esq., CPA | Citrin Cooperman

Steven I. Hurok brings more than 40 years of experience to Citrin Cooperman as a director. Steve provides a wide range of tax advisory services for an array of clients, with a strong expertise in the retail and real estate industries. He has a specialized focus in the areas of executive compensation, estates, and trusts, and is the leading tax advisor to a variety of clients including a major private company that is regularly ranked as one of the “100 Best Companies to Work For” by Fortune. He has also led national tax quality assurance review teams and has served as a spokesperson to the media for tax matters.

Steve is committed to delivering value to clients by designing sound savings strategies. He is highly skilled in addressing all aspects of tax planning, compliance, and tax controversy resolution. Clients also benefit from his ability to create effective solutions for specific tax issues while minimizing consequences in other areas. Before joining Citrin Cooperman, Steve held the role of managing director of taxation at Leon M. Reimer & Co., P.C. Earlier in his career, he held positions including managing tax partner and tax director at international and national firms.

 

Victor-A.-Jaramillo,-Esq._Caplin-&-Drysdale_myLawCLEVictor A. Jaramillo, Esq | Caplin & Drysdale

Victor Jaramillo is a Member in Caplin & Drysdale’s Washington, D.C. office and is a member of the firm’s Board of Directors. He advises multinational corporations, financial institutions, and individual clients on a broad range of tax matters, including tax controversies, risk management and international compliance, and cross-border structuring. He also utilizes his Spanish fluency to advise Spanish-speaking clients. Mr. Jaramillo’s major areas of practice include subpart F, tax treaty issues and competent authority proceedings, FATCA entity classification and compliance, withholding and information reporting, financial products, and individual compliance.

Mr. Jaramillo also advises on the international tax issues of high-net-worth clients with respect to pre-immigration and structuring cross-border investments. He has extensive experience advising both U.S. taxpayers and individuals living abroad with undisclosed foreign assets on U.S. tax compliance issues, especially those with foreign business and trust interests.

 

Stuart-Katz,-Esq._Cohen-&-Wolf,-PC._myLawCLEStuart Katz, Esq | Cohen & Wolf, PC.

Stuart is the only lawyer in Connecticut who has been named “Lawyer of the Year” by the Best Lawyers in America® for representing both Management and Individuals in the area of Employment Law, recognition that reflects his unique experience on both sides of the employer-employee relationship. A strong advocate who brings a strategic, big picture approach to every case, these attributes have been recognized in Chambers USA where sources say: “He works with clients very well and keeps them informed. He is one of my go-to people for employment litigation and is all-around excellent.”

Employment Law

Stuart is chair of the firm’s Employment & Labor Group. He represents employers of all sizes in defending a wide range of discrimination and harassment suits and litigating restrictive covenant, breach of contract, and wage claims. His clients include employers in industries such as healthcare, financial services, higher education, technology, construction, retail, and municipalities.

Stuart also represents professionals and executives in matters relating to their employment. He routinely provides workplace trainings and guidance to employers and employees regarding personnel policies, handbooks, internal investigations, and employee discipline. Stuart’s employment practice includes representation of clients in both state and federal courts, often acting as local counsel for out-of-state law firms and companies. He regularly handles matters before the Connecticut Commission on Human Rights and Opportunities (CHRO), the Equal Employment Opportunity Commission (EEOC), the Department of Labor, and other administrative agencies.

Stuart also serves as an arbitrator and mediator for employment disputes and is a member of the American Arbitration Association’s Panel of Employment Arbitrators.

Commercial Litigation

Stuart is also chair of the firm’s Litigation & Dispute Resolution Group and handles complex business disputes of all kinds. His clients include owners of closely-held businesses, universities, financial services firms, medical and dental practices, and municipalities in cases involving claims of breach of contract, breach of fiduciary duty, violations of the Connecticut Unfair Trade Practices Act (CUTPA), and various business torts. He regularly appears in both state and federal courts and before alternate dispute resolution organizations such as the American Arbitration Association (AAA) and the Financial Industry Regulatory Authority (FINRA), as well as other arbitration and mediation neutrals.

Involvement

In addition to leading firm practice groups, Stuart chairs the firm’s Diversity, Equity & Inclusion Committee. This committee has undertaken a number of initiatives aimed at promoting greater diversity, equity, and inclusion in the legal field, and at Cohen and Wolf. Stuart has previously chaired the firm’s Marketing and Recruitment committees.

Active in his community, Stuart currently serves as president of the board of directors of Camp Ramah in New England. He served for many years as an associate national commissioner and on the regional executive committee of the Anti-Defamation League and on the board of directors of Ezra Academy. He is also a past-President of Temple Beth Sholom in Hamden.

 

Kristen-Rico_Maria-Papageorgiou_myLawCLEAndrew Keyso | Chief, Independent Office of Appeals, IRS

 

 

 

Michele-A.-Lazzara,-CPA,-CGMA,-CBIZ_Marks-Paneth_myLawCLEMichele A. Lazzara, CPA, CGMA, CBIZ | Marks Paneth

Michele A. Lazzara, CPA, CGMA, is a Partner at Marks Paneth LLP. She has more than 20 years of public accounting experience and provides practical, comprehensive planning, consulting and advisory services to clients in a variety of industries.

Her broad background includes experience with corporate/partnership tax planning, financial planning and individual tax planning as well as matrimonial and divorce planning. She has a proven track record serving closely held businesses, nonprofit organizations, professional services firms and clients in the real estate industry. Ms. Lazzara also enjoys working hands-on with high-net-worth individuals and their family offices.

Ms. Lazzara is trained in basic interdisciplinary collaborative law and has spoken on collaborative dispute resolutions. She has also spoken on the tax implications of same-sex marriage.

 

Honorable Diana Leyden_US Tax Court_myLawCLEHonorable Diana Leyden | US Tax Court

Professor Leyden is Special Trial Judge with the United States Tax Court. Judge Leyden started in her current position in June, 2016. Prior to becoming a Special Trial Judge, Judge Leyden served as the first Taxpayer Advocate for the New York City Department of Finance, creating that position and issuing the first Annual Report of the NYC Taxpayer Advocate in May 2016. Prior to that, Judge Leyden was the Director and Clinical Professor for the UConn Law School Tax Clinic, a low-income taxpayer clinic. She created and ran that clinic for 16 years.

Judge Leyden was a former Chair of the ABA Low Income Taxpayer Clinic and the recipient of the ABA Janet Spragens Pro Bono Award in 2005 She has been a frequent speaker on tax practice and procedure and ethics. Judge Leyden also served as a Law Clerk to the Hon. Herbert Chabot, U.S. Tax Court, practiced in private law practice, and worked in two state departments of revenue. She is the author of Advocating for Low Income Taxpayers: A Clinical Studies Casebook and Practice Handboodk (5th ed. 2015) and a contributing author to Effectively Representing Your Client Before the IRS (6th ed.). Judge Leyden is a graduate of the Georgetown University Law Center LL.M. program.

 

Kristin-M.-Lynn,-Esq._Green-&-Sklarz,-LLC._myLawCLEKristin M. Lynn, Esq | Green & Sklarz, LLC

Kristen focuses her practice on trust and estate planning, asset protection, special needs and long-term care planning, business succession planning, and probate. Kristen also handles residential and commercial real estate transactions.

Kristen provides services to individuals, families, fiduciaries, and business owners. She assists clients with wealth transfer strategies designed to minimize overall estate tax while protecting beneficiaries from creditors. Kristen is experienced in drafting wills, revocable and irrevocable trusts, buy-sell agreements, and other estate and business planning documents.

After obtaining her Juris Doctor from Quinnipiac University School of Law in 2007, Kristen went on to attend Georgetown Law School in Washington, D.C. where she earned a master’s degree (LL.M.) in Taxation with a focus in Private Wealth and Estate Planning.

Kristen is a member of the Connecticut Bar Association’s Trust and Estate and Elder Law sections and the Greater New Britain Chamber of Commerce. As an active volunteer with the Alzheimer’s Association Connecticut Chapter, Kristen currently serves as a committee member for the Walk to End Alzheimer’s. She has also served on the Board of Directors for Love of Learning, Inc., a nonprofit educational organization, and the Continuing Legal Education Committee for the Connecticut Bar Association Elder Law Section. Kristen has also volunteered with the Truancy Intervention Project, where she worked with students to address issues contributing to chronic absenteeism.

 

Jason-A.-Marsh,-Esq_Green-&-Sklarz,-LLC._myLawCLEJason A. Marsh, Esq | Green & Sklarz, LLC

For nearly 20 years, Jason has practiced in the areas of general business and corporate law, commercial finance, commercial real estate, land use, promotions, marketing and advertising law, and intellectual property. He has worked with individuals and business of all sizes, from small start-up entities to multi-national corporations.

Areas of Practice

Business & Corporate

Jason counsels his clients regarding proper corporate governance and procedure, and regularly drafts and negotiates the panoply of agreements that arise in connection with the establishment of business entities and the life-cycle of those business. Such agreements include entity formation documents, operating agreements, Bylaws, shareholder agreements, employment contracts, licensing agreements and complex services agreements. He also assists clients with a wide range of transactional matters, including the private offering of securities (i.e., private placements), asset sales and purchases, stock/equity sales and purchases, commercial loan transactions, and business expansions, such as the formation of joint ventures and similar affiliations.

Commercial Real Estate

Jason has represented clients in a wide array of commercial real estate matters relating to the development, financing, leasing, acquisition, and management of nearly all types of commercial real estate. Jason’s finance practice includes representing lending institutions and borrowers in secured lending transactions.

Promotion, Marketing & Advertising

Jason advises clients on such matters as design, structure and execution of contests, sweepstakes and other games of chance, the review of advertising claims for legal compliance, the drafting and review of web site terms and conditions and privacy policies, and the development and execution of “cause” marketing promotions and commercial co-venture arrangements. He also drafts and negotiates agreements including marketing service agreements, sponsorship agreements and license agreements. In addition, Jason conducts seminars regarding games of chance and claim substantiation.

Intellectual Property / Copyright & Trademark

Jason regularly advises clients regarding the acquisition, exploitation and protection of intellectual property rights, with a particular emphasis on copyright and trademark law. With respect to trademarks, this includes: pre-screening trademarks for preliminary clearance; research and analysis of trademarks for federal and state availability; preparation and prosecution of federal and state trademark applications; preparation of international trademark registrations through the Madrid Protocol; prosecution of matters before the Trademark Trial and Appeal Board, including trademark opposition and cancellation proceedings; domain name searches, acquisitions and dispute resolution; advising clients on proper use, maintenance, protection and exploitation of marks; drafting and negotiating intellectual property licensing agreements.

 

Daniel-Mayo,-JD,-LL.M._Withum_myLawCLEDaniel Mayo, JD, LL.M. | Withum

Daniel has more than 20 years of professional tax experience as well as experience in federal, international and financial products taxation. He is experienced in mergers and acquisitions, capital markets and cross-border transactions.

Daniel is a frequent author and speaker on U.S. Federal income tax and international tax topics. He is an approved arbitrator for FINRA and an adjunct faculty member with Georgetown University Law Center. Daniel is a member of the American Bar Association, previously the chair of the Banking & Savings Institutions Tax Committee, and the New York Bar Association.

 

Guinevere-M.-Moore,-Esq_Moore-Tax-Law-Group_myLawCLEGuinevere M. Moore, Esq | Moore Tax Law Group

Guinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies. She advocates for taxpayers at the IRS examination and appeals levels and, if a settlement with the IRS cannot be reached, in litigation. She is also the Executive Director of US Partnership Representative, Inc., and in that role she serves as a professional partnership representative.

Ms. Moore has represented taxpayers throughout her career, and draws on her experience in working with her clients, with the IRS, and with opposing counsel to help craft and execute the best possible plan to resolve the issues her clients are facing. Ms. Moore has successfully defended taxpayers against assessment of all types of federal tax, including income tax, employment tax, estate tax, gift tax, civil penalties, and criminal penalties.

Ms. Moore’s significant experience in practicing before the IRS and in the United States Tax Court enables her to work together with her clients to determine the best path forward to resolving the tax dispute – whatever Internal Revenue Code section may be at issue. The Internal Revenue Code contains thousands of provisions, and no tax professional has encountered them all. But having years of experience with the procedural hurdles that a taxpayer has to jump through in order to resolve a disagreement with the IRS over how much tax is due facilitates a much easier journey towards agreement or resolution through litigation.

Ms. Moore particularly enjoys the client counseling that she performs in her role as a taxpayer’s advocate. Having navigated hundreds of disputes with the IRS she is able to guide clients through what is often the most difficult crisis they are facing in their lives. Her clients will never wonder what comes next, or how the most recent development will impact them, because Ms. Moore routinely explains the process, the anticipated timeline, our strategy, and how all of the pieces come together. Ms. Moore will either partner with a client’s existing accountant, or, if necessary, engage a new accountant under a Kovel agreement.

Ms. Moore is actively involved in the American Bar Association, Section of Taxation. She is the immediate past Chair of the Standards of Practice Committee of the Section of Taxation. ABA Tax Times recently published an interview with Ms. Moore. Ms. Moore is also actively involved in the Accounting and Financial Women’s Alliance (AFWA), where she served as a member of the Board of Directors.

Ms. Moore draws on her many years of experience as a member of the Tax Bar to provide advice and insight to others. She is a co-author of Incompetent Authority, (a play on Competent Authority, the person legally designated authority to opine on matters of double taxation), a humorous advice column for tax lawyers published in ABA Tax Notes.

Ms. Moore is a frequent speaker at national and local conferences on topics related to tax, ethics, and the ethics of tax. Ms. Moore launched what has become an active pro bono program designed to help low income taxpayers receive representation that they could otherwise not afford. As part of this process, she co-authored and designed a four-part training series for representing low-income taxpayers before the IRS. She has been recognized for her pro bono work as the volunteer of the year by LadderUp, and has represented over one hundred clients pro bono.

Ms. Moore lives in Chicago with her husband and her four children. While she lives in Chicago, she represents taxpayers all across the United States and the world.

 

Roger Nemeth, EA  | Tax Help Software

Roger has been doing taxes since 2006. During that time he has been the General Manager for a large franchise in Atlanta as well as a Technology Manager for several tax franchises. Roger obtained his Enrolled Agent Status in 2011. Roger is also an NTPI Fellow. Prior to getting into taxes Roger worked as a Deputy Sheriff in Leon County Florida for 8 years. Roger was injured in the line of duty and moved into the tax field. He was awarded the Medal of Valor and Purple Heart by the Florida Sheriff’s Association.

 

Fran-Obeid,-Esq_MFO-Law-PC_myLawCLEFran Obeid, Esq | MFO Law PC

Fran Obeid is the founder of MFO LAW, P.C. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the tax division of the Department of Justice, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General as well as other government agencies.

Ms. Obeid has represented numerous clients residing throughout the world with undisclosed offshore accounts advising on disclosure and compliance alternatives and guiding them through the process. She defends clients in federal and state audits, including residency and sales tax audits and advises on how to prevent such audits.
Ms. Obeid represents non-filers; alleged responsible persons and has successfully obtained significant abatements of penalties.

Ms. Obeid has represented individual witnesses and accounting firms before the U.S. Attorney’s Office, the Criminal Investigation unit of the IRS as well as before the New York State Attorney General. She regularly interacts with revenue officers and agents, IRS Appeals officers, IRS Counsel, criminal investigators, Assistant United States Attorneys and Assistant Attorney Generals, taking the right approach to best meet the client’s needs, whether it be defending a civil examination, criminal investigation or indictment, or subpoena demand.

 

Nina-Olson_Center-for-Taxpayer-Rights_myLawCLENina Olson | Center for Taxpayer Rights

Nina E. Olson is the Executive Director of the Center for Taxpayer Rights. From March 2001 to July 2019, Nina served as the National Taxpayer Advocate of the United States, an independent organization within the Internal Revenue Service , dedicated to assisting taxpayers resolve their problems with the IRS and making administrative and legislative recommendations to mitigate those problems systemically. She has submitted 39 annual reports to Congress, and testified before congressional committees over 60 times. Before serving as the National Taxpayer Advocate, Nina founded and directed The Community Tax Law Project, the first independent Low Income Taxpayer Clinic in the US. She also maintained a private legal practice, representing taxpayers in disputes with the IRS.

Nina has received many awards and recognitions, including the American Bar Association Section of Taxation’s Distinguished Service Award for Lifetime Service, Pro Bono Award, and Jules Ritholz Memorial Merit Award for Outstanding Dedication, Achievement, and Integrity in the Field of Civil and Criminal Tax Controversies; the Tax Foundation’s Public Sector Distinguished Service Award; and Pro Bono Awards from the Virginia State Bar, the Virginia Bar Association, and the City of Richmond Bar Association. In 2016 she was recognized by Tax Analysts as one of the Top 10 Outstanding Women in Tax (internationally).

Nina received her LLM in Taxation from Georgetown University Law Center, her JD from North Carolina Central University School of Law, and her AB (in fine arts) from Bryn Mawr College.

 

Damon-Rowe,-Esq_Meadows,-Collier,-Reed,-Cousins,-Crouch-&-Ungerman,-LLP_myLawCLEDamon Rowe, Esq | Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP

Damon Rowe joins Meadows Collier after two decades of service at the IRS. His practice focus is White-Collar Crime, Tax Controversy and Government Regulatory Litigation. He has expertise in many areas including cryptocurrency, financial crimes, civil and criminal tax, money laundering, fraud, internal investigations and the Bank Secrecy Act.

Mr. Rowe began his career at the IRS in 1998 as a Special Agent and held numerous leadership positions for the agency. He served as the Special Agent in Charge for both the Los Angeles and Dallas Field Offices in the Criminal Investigation Division. This office investigates a diverse mix of financial investigations, including cybercrime, international tax fraud, identity theft, public corruption and Bank Secrecy Act.

His next leadership position was Executive Director of International Operations in the Criminal Investigation Division. He successfully designed and implemented novel
strategies to detect and mitigate international financial crimes, devised an international financial crime strategy used to train and educate thousands of global investigators in over 50 countries. His most recent position was Executive Director of the Office of Fraud Enforcement. While in this position, International and Domestic fraud threat mitigation strategies were developed and implemented for all IRS business operating divisions. This office implemented a four-pillar intelligence model which aided in fraud detection. He led the COVID Relief Fraud Project and the Joint International Task Force.

Damon Rowe is currently an Adjunct Professor at Texas A&M University School of Law, where he teaches a course in international white-collar crime.

Mr. Rowe received his LL.M in Tax from SMU Dedman School of Law and his J.D, from Texas Southern University Thurgood Marshall School of Law. He graduated from the University of Houston with a B.S. in Accounting. Mr. Rowe was admitted to the Texas Bar in 1992.

 

Lawrence-A.-Sannicandro_McCarter-&-English,-LLP._myLawCLELawrence A. Sannicandro | McCarter & English, LLP

Larry has favorably resolved hundreds of federal and state tax controversies, many of which involved sophisticated and complex tax issues that established legal precedent.

Lawrence (Larry) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.

Drawing on his unique experience as a former estate and gift tax attorney for the IRS, Larry is particularly well-versed in estate and gift tax planning techniques, as well as the valuation of closely held businesses, and defending those techniques and valuations in disputes with tax authorities. He also counsels clients on all facets of estate, business, and tax planning, including the formation, operation, transfer, and termination of business entities.

Larry is a past Chair of the Tax Collection, Bankruptcy and Workouts Committee of the American Bar Association (ABA) Section of Taxation. He currently serves as a member of the ABA Section of Taxation’s Appointments to the Tax Court and Pro Bono Committees. On behalf of the ABA Section of Taxation, he has drafted comments to Congress, the IRS, and the U.S. Department of the Treasury on a wide range of tax issues, such as reforming the procedures for auditing and litigating against partnerships and the need to adopt a voluntary disclosure program for unreported cryptocurrency transactions. For his service to the ABA, Larry was awarded the John S. Nolan Fellowship.

Larry also teaches a course in tax practice and procedure as an adjunct professor at Fairleigh Dickinson University, and he has taught classes on corporate tax, partnership tax, legal ethics, and negotiations as an adjunct professor at Pace University and a lecturer at Georgetown University Law Center and Rutgers Law School.

Larry is a dedicated pro bono advocate who uses his tax expertise to give back to the community. He works with the After Innocence organization to provide tax-related advice to wrongfully convicted individuals. For his work in co-designing and co-implementing an entirely new form of low-income taxpayer assistance, the ABA Section of Taxation awarded Larry the 2020 Janet Spragens Pro Bono award, the Section of Taxation’s highest award for pro bono. Larry also regularly appears on behalf of taxpayers as part of the New York County Lawyers Association’s U.S. Tax Court Calendar Call Program. The New York County Lawyers Association awarded Larry its Pro Bono Award in 2015. Larry also proudly serves as a trustee of Integrity House, one of the largest non-profit providers of substance use disorder treatment in New Jersey.

Prior to entering private practice, Larry served as a law clerk for the United States Tax Court. He earned his LLM in Taxation from Georgetown University Law Center, his JD from the University of Florida Levin College of Law, and his MBA in Finance from Binghamton University.

Larry is a frequent author on tax practice and procedure, having published articles in the Journal of Tax Practice and Procedure, Tax Notes®, Tax Notes (including Tax Notes State), TAXES – The Tax Magazine®, and The New Jersey Law Journal, among other regarded periodicals. He is the author of the BNA Tax Management Portfolio on Innocent Spouse and a co-author of Qualified Appraiser, Qualified Appraisal: Practice, Procedure, Legal Analysis, and Theory (John Wiley & Sons, Inc. 2017), and Tax Practitioner’s Guide to Identity Theft (CCH, Inc. 1st ed. 2015; 2d ed. 2016). He is also a contributing author to the Effectively Representing Your Client Before the IRS (Chapter 10 of the ABA Section of Taxation’s book).

 

Michael-Sardar,-Esq_Kostelanetz-&-Fink_myLawCLEMichael Sardar, Esq | Kostelanetz & Fink, LLP

Michael Sardar has extensive experience on a wide range of tax controversy and white collar criminal defense matters. Mr. Sardar represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.

Mr. Sardar also represents and advises taxpayers facing audits and investigations of noncompliance with IRS foreign bank and asset reporting requirements, utilizing his skill, creative thinking, and deep knowledge of the law in this area. In addition, Mr. Sardar has a great deal of experience representing corporate and individual taxpayers making voluntary disclosures of unreported income to the IRS and state tax authorities. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.

Mr. Sardar represents clients in criminal tax investigations, including those involving allegations of willful nondisclosure of foreign bank accounts and under-reporting of income. He also represents clients in various white collar criminal matters, such as customs fraud and bank fraud, and he advises clients in connection with internal investigations regarding corporate and entity noncompliance. Mr. Sardar represents taxpayers in New York State and City residency audits and investigations, including those involving the sourcing of income for multi-state taxpayers, and he has represented clients in connection with tax investigations conducted by the New York State Attorney General’s Office. Mr. Sardar has also advised many nonprofit organizations on federal and state tax issues including general tax exemption and Unrelated Business Income Tax (UBIT).

Mr. Sardar joined Kostelanetz & Fink in 2009, and was named partner in January 2019. Prior to joining Kostelanetz & Fink, Mr. Sardar was an attorney with Heller Ehrman LLP, where his practice was focused on transactional tax matters.

Mr. Sardar is Co-Chair of the Federal Bar Association (FBA) Section on Taxation, New York Chapter. He also serves as Co-Chair of the Subcommittee on Offshore Enforcement of the ABA Committee on Civil and Criminal Tax Penalties. He is a former Vice-Chair of the New York County Lawyers’ Association (NYCLA) Taxation Committee. Mr. Sardar lectures and writes frequently on tax controversy topics, including foreign asset reporting and non-compliance.

Mr. Sardar graduated summa cum laude from Baruch College in 2004 with a bachelor’s degree in Business Administration, and received his law degree from Cornell University Law School in 2007.

 

Jeffrey-M.-Sklarz,-Esq._Green-&-Sklarz,-LLC_myLawCLEJeffrey M. Sklarz, Esq | Green & Sklarz, LLC

Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs including: bankruptcy/bankruptcy litigation, creditor/debtor litigation, tax litigation, and commercial litigation. He regularly tries cases and appeals before Connecticut’s state and federal courts. Jeff has particular experience regarding the interplay between bankruptcy and tax law.

Jeffrey M. Sklarz was named the Best Lawyers® 2022 Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law “Lawyer of the Year” in New Haven and was included in the 2021 Edition of The Best Lawyers in America© for Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law. He is a Fellow of the American College of Tax Counsel (ACTC). Jeff is a 2005 recipient of the Connecticut Law Tribune’s New Leaders of the Law Award (Overall Achievement, Fairfield County) and has been listed by New England Super Lawyer® as a Super Lawyer (Business Litigation) since 2010 (Rising Star 2010-2013) and was named a Fellow of the American Bar Association, Business Law Section (2011 – 2013).

Jeff received his B.A. in government from Colby College, his J.D. from the University of Connecticut, School of Law, and his LL.M. (Taxation) from Boston University, Graduate Tax Program.

Jeff holds (and has held) many positions with local and national bar organizations and is a frequent writer and lecturer on topics involving bankruptcy, tax litigation and commercial litigation. Current positions include: Chair of the Bankruptcy Study and Reform Committee of the American Bar Association, Business Law Section, and Program Director for the American Bar Association, Business Law Section, Business Bankruptcy Committee. Jeff is also currently President of the New Haven Jewish Community Center.

Jeff is frequent lecturer and writer on topics involving bankruptcy and tax. He is also the co-founder of the New England IRS Representation Conference.

 

Kristen-Rico_Maria-Papageorgiou_myLawCLERichard Tierney | Deputy Director of Exam, IRS

 

 

 

J.-Robert-Turnipseed,-Esq._Ambrecht-Jackson,-LLP_myLawCLEJ. Robert Turnipseed, Esq | Ambrecht Jackson, LLP

Robert’s practice focuses primarily in the areas of taxation and tax planning, trusts and estates, tax controversies (state and federal), business succession planning, business transactions, mergers and acquisitions, bankruptcy, and probate. He joined the firm as a partner in 2011. He is a 1993 graduate of Auburn University, where he received a Bachelor of Arts degree in English, with a concentration in Technical and Professional Communication. Robert received his law degree in 1996 from the Cumberland School of Law at Samford University, and thereafter received an L.L.M. in Taxation from the University of Alabama School of Law, graduating with High Honors. He served as a law clerk for Justice Reneau Almon of the Alabama Supreme Court in 1996, and has been in private practice since 1997.

Robert currently serves as Council Director for the Section of Taxation for the American Bar Association (“ABA”), having been appointed the position in 2019. He is the Past Chair for the Closely Held Business Committee of the ABA Section of Taxation, and has been a speaker or panel participant both locally and nationally on a variety of tax and business planning topics. Robert is the Immediate Past Chair for the Alabama State Bar Association Tax Section. He is a member of the Estate Planning Council of Mobile and is a current member and past Vice Chair of the Probate Section of the Mobile Bar Association. He is also a member of Class 6 of the Alabama State Bar Leadership Forum (2009) and was recognized as a ‘Rising Star’ by Alabama Super Lawyers in 2011.

Robert was inducted into the Fellows of the American Bar Association in 2015. In 2019, he was elected to the American College of Tax Counsel (“ACTC”), which is a national association of tax lawyers who have been recognized by their peers as making an exceptional contribution to the tax profession.

Robert is licensed to practice in all state and federal courts in Mississippi and Alabama, as well as the Fifth and Eleventh U.S. Circuit Courts of Appeal.

 

Michael-A.-Villa-Jr.,-Esq_Meadows,-Collier,-Reed,-Cousins,-Crouch-&-Ungerman,-LLP_myLawCLEMichael A. Villa Jr., Esq | Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP

Mike was named a Texas Super Lawyer in Texas Monthly and Texas Super Lawyer Magazines in 2013-2021. In 2010-2013, he was named a Texas Rising Star. Mike focuses on resolving federal tax controversies and white collar crime, including securities, tax and bank fraud. He represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation, as well as in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, business torts, and other commercial disputes.

Prior to joining the firm in 2007, Mike worked in Washington, D.C. as a Congressional intern to U.S. Senator John Breaux (Retired) and worked as an Associate with a regional law firm in New Orleans, Louisiana. In 2004-2005, he served as a Judicial Clerk to the Honorable James J. Brady, U.S. District Court, Middle District of Louisiana.
Mike was admitted to practice in Texas in 2005 and in Louisiana in 2004.

 

Anthony-F.-Vitiello,-Esq._Connell-Foley_myLawCLEAnthony F. Vitiello, Esq | Connell Foley

Anthony Vitiello’s practice is dedicated to sophisticated tax planning for individuals, businesses, estates and trusts. As Chair of the firm’s Taxation and Estate Planning Practice Group, he places a particular emphasis on tax-driven estate planning and asset protection planning. Tony uses a personalized and innovative approach in planning estates from $10 million to more than $1 billion, and in his counsel on significant tax issues for family foundations, closely held corporations, partnerships and limited liability companies. He also maintains a significant practice in gift, estate and income tax audits and controversies.

Since 2011, Tony has been listed annually in The Best Lawyers in America®, one of the legal profession’s most well-respected and long-standing peer-review publications. He is recognized by Best Lawyers® in the areas of Trusts and Estates, Trusts and Estates Litigation, and Tax Litigation and Controversy. Tony was also named by editors of Worth magazine in its list of the nation’s “Top 100 Attorneys” for each of the four years the roster was published. Worth’s editors looked most carefully at attorneys practicing in trusts and estates and other personal planning matters.

A thought leader in estate planning and related tax matters, Tony lectures extensively and frequently publishes in legal and business journals.

Tony began his legal career with the United States Treasury, providing counsel to the Internal Revenue Service (IRS). During this time, he represented the IRS in the United States Tax Court, handling complex tax controversies including corporate tax disputes, estate tax litigation matters and personal income tax cases. Tony received both his J.D. and LL.M. in taxation from New York University (degree programs ranked sixth and first in the nation, respectively).

 

Philip-J.-Wilson_Marcum-LLP_myLawCLEPhilip J. Wilson, CPA | Marcum

Philip Wilson is office managing partner of Marcum’s Costa Mesa, California, office and is leader of the Firm’s national Tax Controversy group. Mr. Wilson has more than 30 years of CPA and business advisory experience, including experience as an IRS revenue agent.

Mr. Wilson focuses on helping individuals and companies resolve tax controversies with the Internal Revenue Service, representing all types of businesses as well as high net worth individuals.

Prior to joining Marcum LLP, Mr. Wilson was a founding partner of WilsonMorgan LLP, based in Irvine. He oversaw all of the firm’s tax compliance, tax consulting, and tax controversy engagements. He has substantial experience in the real estate area, including tax structuring for commercial and residential developers, and has worked with clients in a wide variety of industries.

 

Beverly-Winstead,-Esq._Low-Income-Taxpayer-Clinic,-University-of-Maryland-School-of-Law-and-Law-Offices-of-Beverly-Winstead,-PC_myLawCLEBeverly Winstead, Esq | Low Income Taxpayer Clinic, University of Maryland School of Law and Law Offices of Beverly Winstead, PC

Beverly Winstead, Esq., is an accomplished and award-winning tax attorney, law professor, philanthropist, and public speaker, bringing unmatched legal experience and a persistent focus on creating positive financial outcomes for her clients. Her tenacity on the court led to her induction into the Sports Hall of Fame at her University. That tenacity aides her in resolving disputes with the Internal Revenue Service (IRS) and state tax agencies, and helps her reduce — sometimes even eliminate — her clients’ tax debts. The firm provides counsel for individuals, corporations, and nonprofits; handles litigation in the U.S. Tax Court and in Maryland courts for civil tax matters.

The firm also offers legal services in negotiations, settlements, assessments, and client counseling. Beyond tax resolution, The Firm offers business structure advice, estate planning, and financial asset protection. She has served as Director of the Low Income Taxpayer Clinic at the University of Maryland Francis King Carey School of Law, where she is an Adjunct Law Professor.

 

Jeffrey Dirmann, Esq_Agostino & Associates PC_myLawCLECaren Zahn, EA | Agostino & Associates

26 years with Agostino & Associates P.C., representing individual and business taxpayers in all administrative levels of the Internal Revenue Service, State, and Local taxing authorities.

Certifications: Enrolled Agent

Expertise: offers-in-compromise, installment agreements, innocent spouse, penalty abatements, tax returns, tax return compliance, non-filers, audits, voluntary disclosures.
Co-Director and Administrator of Taxpayers Assistance Center, Inc. (TAC) www.tacnj.org. TAC provides pro bono representation to low income taxpayers before all administrative levels of the IRS and State taxing authorities.

 

IRS_Logo_myLawCLEMargaret Romaniello | Senior Stakeholder Liaison, IRS

 

 

 

IRS_Logo_myLawCLEJoseph McCarthy | Senior Stakeholder Liaison, IRS

 

 

 

myLawCLE-Logo-2Paul Greenberg, CPA | Ritch, Greenberg & Hassan

A second-generation accountant, Paul Greenberg has been a member of the firm since 1973. A native of New Haven, Connecticut, Mr. Greenberg received his degree from Bentley College. Paul is a member of the American Institute of Certified Public Accountants, Connecticut Society of Certified Public Accountants, and Massachusetts Society of Certified Public Accountants. Paul is on the Board of Directors at the Ronald McDonald House and the Board of Directors at the Jewish Home for the Elderly.

Paul has assisted privately held companies as Acting Interim CFO, managing their financial functions in addition to preparing loan and equity raising packages. Providing assistance with Financial Due Diligence in Merger and Acquisitions is another area that Paul has had extensive experience. He currently acts as Advisor to CEO and Boards of Directors on financial matters.

 

Richard-J.-Sapinski_Sills-Cummis-&-Gross-PC_myLawCLERichard J. Sapinski | Sills Cummis & Gross P.C.

Richard J. Sapinski is Co-Chair of the Firm’s Tax Fraud and Controversy Practice Group. His practice involves white collar criminal defense on both federal and state levels and civil and criminal tax litigation, as well as international tax reporting and compliance issues. Prior to joining the Firm, Mr. Sapinski was employed by the Office of the District Counsel, Internal Revenue Service, Newark, New Jersey as a trial attorney from 1977 to 1984 and later with the Office of the Regional Counsel Internal Revenue Service, Philadelphia, Pennsylvania, as a Special Trial Attorney from 1985 to 1987.

In the latter position, Mr. Sapinski was assigned responsibility for litigating in the United States Tax Court on behalf of the Commissioner of Internal Revenue in large and sensitive cases and for assisting IRS international examiners in developing international tax issues for litigation. He litigates matters in the United States District Court, U.S. Tax Court and the Superior Court and Tax Court of New Jersey and the Federal and State Appellate Courts. He also represents professionals before disciplinary and licensing boards and handles administrative matters involving the Examination, Collection and Criminal Investigation divisions of the Internal Revenue Service and their state counterparts.

 

IRS_Logo_myLawCLEKristy Moquin | Deputy National Taxpayer Advocate, IRS

 

 

 

Robert M. Finkel_ Moritt Hock & Hamroff LLP._myLawCLERobert M. Finkel | Moritt Hock & Hamroff LLP

Robert M. Finkel is the Partner-in-Charge of the firm’s New York City office where he also serves as Chair of its Tax Practice Group.

Mr. Finkel has over 35 years of experience as a tax and business lawyer. His practice focuses on the areas of individual and business taxation including tax controversy and tax litigation.

Mr. Finkel advises clients on the tax aspects of a wide range of business transactions including mergers and acquisitions, private equity and real estate transactions. He also advises Israel-based high-tech companies on US operations and financings, and advises not-for-profit and charitable organizations on a variety of issues.

In addition, he represents clients in audits and other controversies before the Internal Revenue Service, state and other taxing authorities, as well as in all phases of the litigation before the United States Tax Court and the Massachusetts Appellate Tax Board.

Mr. Finkel has been an adjunct professor at Boston University School of Law’s Graduate Tax Program since 1995. He was an adjunct Professor at the Radzyner Law School (IDC Herzliya, Israel) where he taught U.S. corporate and tax law (2005-2006).

Prior to private practice, Mr. Finkel was a senior trial attorney with the Office of the Chief Counsel of the Internal Revenue Service.

 

Jason Freeman_ Freeman Law_myLawCLEJason Freeman | Freeman Law

Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney.

Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States and to U.S. News and World Report’s Best Lawyers in America list. He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award. Mr. Freeman was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI.

Mr. Freeman has been recognized multiple times by D Magazine , a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service. He has previously been recognized by Super Lawyers as a Top 100 Up-And-Coming Attorney in Texas.

Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). He is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas). Mr. Freeman also served multiple terms as the President of the North Texas chapter of the American Academy of Attorney-CPAs. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40).

Mr. Freeman serves on the law school faculty at SMU’s Dedman School of Law, where he has taught a course in the law of federal income taxation for nearly a decade, and he is a frequent public speaker across the country, presenting and educating on various legal topics.

He is also a Forbes contributor for tax and white-collar legal matters.

Mr. Freeman represents clients in litigation and disputes, with a particular focus on federal and state tax controversies, as well as white-collar and financial disputes, both civil and criminal. He handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges. He also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements, as well as cryptocurrency and Blockchain matters.

Mr. Freeman serves as trial counsel in complex business and commercial disputes, trying cases to juries and to the bench. He is experienced in civil cases involving an array of disputes, including fraud, breach of fiduciary duty, civil RICO, executor and trustee litigation, complex probate litigation, negligence, trade secrets, partnership disputes, breach of contract, and other matters.

Mr. Freeman frequently serves as an expert witness. He also represents professionals—including attorneys and CPAs—before regulatory boards and in disciplinary hearings.

Leveraging his CPA background, Mr. Freeman often represents clients in complex financial and regulatory matters that involve sophisticated forensic accounting analyses. He has handled hundreds of IRS audits and other investigations and has represented clients facing a broad array of tax and white-collar or financial-related charges, including tax evasion, bank fraud, money laundering, Bank Secrecy Act violations, securities fraud, computer intrusion and Medicare fraud, as well as clients in disputes with the Securities & Exchange Commission (SEC). He also represents clients in asset forfeiture cases.

Mr. Freeman’s litigation experience includes serving as trial counsel in a criminal tax evasion and conspiracy jury trial in the Federal District Court for the United States Virgin Islands. In addition, Mr. Freeman represents clients in appellate matters, serving as lead appellate counsel, presenting oral argument in a case before the United States Court of Appeals for the Third Circuit.

Agenda

DAY 1 – Thursday, November 17, 2022

Straight Talk on Security Six: What Every Tax Pro Must Consider – Margaret Romaniello, Joseph McCarthy, Paul Greenberg, and Moderator – Eric L. Green | 10:30am – 12:00pm

As the busy year end and tax season approaches, it’s critical to ensure you are taking all possible precautions to secure your firm, protect your clients’ data, and stay in compliance with IRS guidelines and regulations for tax and accounting professionals.

Attend this special panel discussion to hear directly from the IRS about what the implementation of the “Security Six” recommendations should really look like in your firm and to learn about the cornerstones of creating a plan to satisfy the FTC’s Safeguard Rule for PTIN holders.

Lunch | 12:00pm – 1:00pm

The IRS Exam: Who Should Deal with the Revenue Agent? – Fran Obeid, Walter Pagano, Richard J. Sapinski, and Moderator – Sara V. Spodick | 1:00pm – 2:00pm

So, the exam notice arrived, and the client is very concerned. As the return preparer this is not a problem, just gather the records and handle the exam, right? What if it’s not so routine…. “You see, a bunch of those expenses…well they might have been made up…and lets not bring up the cash that did not make it into the POS system…” Our panel of experts will review how to handle the routine and not-so-routine exam and what role each person should play: the original preparer, the dummy accountant, the Kovel accountant, and the criminal tax attorney.

Challenging Tax Penalties – Michael Sardar, Beverly L. Winsted, Roger Nemeth, and Moderator – Eric L. Green | 2:00pm – 3:00pm

Those late-night commercials make it sound just so easy, but how do you get rid of tax penalties? This program will cover many of the frequently assessed civil penalties and additions to tax assessed by the IRS, and the various grounds upon which practitioners seek abatement. The program will cover administrative waivers (referred to as “First Time Abatement”), the defenses of reasonable cause and substantial compliance, and best practices to avoid penalties during the audit. The program will cover IRS Account Transcript analysis to determine if First Time Abatement applies, strategies for documenting your client’s case for reasonable cause, and preparing and taking an initial denial of penalty abatement to IRS Appeals.

Break | 3:00pm – 3:15pm

US Tax Court: Considering Supervisory Approval and Reasonable Cause – Frank Agostino, Caren Zhan, William Bogardus, Philip J. Wilson, and Honorable Diana Leyden| 3:15pm – 5:00pm

Join us for a front row seat to observe a taxpayer and their representative challenge civil tax penalties in the United States Tax Court on the grounds that the IRS failed to properly approve the penalties under IRC 6751(b) and, in the alternative, that the taxpayer acted with reasonable cause. After the hearing, you will hear from the judge as she addresses the arguments raised and renders a decision. Finally, our panelists will conduct a debrief with the audience, discussing best practices.

DAY 2 – Friday, November 18, 2022

IRS Update – Commissioner Amalia C. Colbert / Interviewed by Jeffrey M. Sklawz, Andy Keyso/ Interviewed by G. Michelle Ferreira, Kristy Moquin/ Interviewed by Lisa E. Perkins | 8:35am – 10:00am

Hear directly from the IRS Executives what to expect from the IRS this coming year.

Break | 10:00am – 10:10am

Enforcement Trends: Crypto, Conservation Easements, Micro-captives, Marijuana – What’s Hot and What’s Not! – Daniel Mayo, Victor A. Jaramillo, Richard Tierney, and Moderator – Guinevere M. Moore | 10:10am – 11:00am

Our panel will review the current trends in IRS enforcement, discuss the IRS Dirty Dozen and latest LB&I Campaigns, and what to expect in the coming year.

Ethics: The Ethical Issues Around Whistleblowing: Can We, or Can’t We? – Walter Pagano, Karen L. Hawkins, and Moderator – Eric L. Green | 11:00am – 12:00pm

According to the Commissioner, our nation’s tax gap is approximately $1 trillion. While a portion of the gap is attributable to taxpayers who are simply unable to pay tax due and owing, much of the gap is the result of intentional conduct – abusive transactions, false returns, evasion of assessment, evasion of payment, and other knowing violations. What can you do if your client knows about tax crimes being committed under their watch? They can strike a blow for justice, help the American tax system, and get paid to do it. Nothing more American than that! But what if the target is a client? Can we ethically blow the whistle on a client, former client, potential client, or related third parties? Our panel of experts will review the whistleblower program and discuss the various ethical issues surrounding both representing the whistleblower as well as becoming a whistleblower yourself, and what you can and cannot do.

Lunch | 12:00pm – 12:45pm

Track A: The Tax and Non-Tax Pitfalls of Liquidating the Business – Robert M. Finkel, Robert Turnipseed, Michele A. Lazzara, and Moderator – Jason A. Marsh | 12:45pm – 1:45pm

Remember that new business venture where everyone was ready to launch the next Amazon? Guess what? Things did not go quite as well as they had hoped, and now the business, business relationships, and even their own financial plans are quickly dissolving into a mess and the closing of the business. Our panel will discuss the various tax and non-tax issues clients will need to face when the business breaks up and how practitioners can help their clients navigate the situation and avoid it becoming more of a mess than it already is.

Track B: Estate & Gift Update Part 1: IRS Challenges to Your Client’s Best-Laid Plans – Kristin M. Lynn, Anthony F. Vitiello, Barry Fischman, and Moderator – Lawrence A. Sannicandro.

SLATs, GRATs, IDGTs and ILITs. Terrific planning techniques that, when set up and managed correctly, can save millions of dollars in estate taxes, and transfer the family business and wealth to the next generation. What happens when the IRS and/or state tax authorities show up and disagree? Our panel will review issues surrounding the most popular estate planning techniques and what practitioners should look for when clients decide to get their “financial house” in order and do their planning, and what to do when the letter from Uncle Sam arrives to review the planning.

Track A: From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime – Philip J. Wilson, Steven Hurok, G. Michelle Ferreira, and Moderator – Caroline D. Ciraolo | 1:45pm – 2:45pm

Audits of partnerships and other pass-through entities were previously governed by special procedures under the Tax Equity and Fiscal Responsibility Act (TEFRA). For tax years 2018 and forward, however, partnership and pass-through audits will be governed by the new Centralized Partnership Audit Regime. The new regime is dramatically changing the way audits are handled and practitioners must understand the new rules to effectively represent their clients and avoid costly mistakes. This panel will discuss the new regime governing partnership and pass-through audits and the complexities of transitioning between TEFRA and the new rules. The panel will also suggest ways to prepare for and effectively manage a partnership audit under the new rules.

Track B: Estate & Gift Update Part 2: Pitfalls When Handling the Estate and Why the Tax Returns Matter! – Frank Angostino, Kristin M. Lynn, Jason Freeman, and Moderator – Zhanna A. Ziering.

Hidden offshore bank accounts, a second set of books, unreported taxable gifts, and fraudulent income tax returns. Pitfalls for the unwary practitioner attempting to assist clients with probating their loved-one’s estate. This program will cover the key issues that need to be addressed, the questions that should be raised, and best practices in remediating past misdeeds. The program will also cover the obligations of executors and administrators under the Federal Priority Act that must be satisfied prior to any distributions to avoid personal liability for those pesky tax issues.

Break | 2:45pm – 3:00pm

Track A: Representing Clients Before a Resource-Challenged IRS – Nina E. Olson, Sara V. Spodick, Lisa E. Perkins, and Moderator – Amanda Evans | 3:00pm – 4:00pm

The challenges of dealing with the IRS persist and have now drawn the attention of Congress. Our panel will review the ongoing issues and what practitioners should be doing with the IRS after filing returns, including the IRS’s suspension of sending certain letters and what that actually means, tax returns that have yet to be processed, resolving disputes over the child tax credit and reconciliation with the Advance CTC, tax liens and payoff letters, and Freedom of Information Act Request responses, among other issues.

Track B: Defending You! Preparer Penalties and Referrals to the OPR – Karen L. Hawkins, Guinevere M. Moore, Sandford J. Boxermann, and Moderator – Eric L. Green.

IRS examiners have become very aggressive in pursuing preparer and appraisal penalties when it believes the professional crossed the line. This decision to penalize the professional can be for anything from disagreeing with the valuation you arrived at or even failing to file your own tax returns. These penalties, once paid, will lead to an automatic referral to the IRS Office of Professional Responsibility. The panelists will review the commonly assessed civil penalties, the assessment procedure and applicable statutes of limitations, the right to and procedure for administrative and judicial appeals, and what steps to take with respect to an OPR referral.

Track A: Confessions of a Tax Evader: Resolving Criminal Tax Cases with Guilty Pleas – Anastasia King, Barbara T. Kaplan, Damon Rowe, and Moderator – Jeffrey M. Sklarz | 4:00pm – 5:00pm

IRS Criminal Investigation and the DOJ Tax Division have an impressive conviction rate. As a result, many taxpayers who are the target of a criminal investigation or who have been indicted are well served to consider resolving their prosecution with a guilty plea. This panel will examine some of the considerations that go into deciding whether a taxpayer should plead guilty and the techniques for negotiating the plea. The panel will also review the impact of tax loss and why the role of the Kovel accountant is so critical.

Track B: Gotcha! Challenging Tax Penalties on International Forms – Miri Forster, Laura L. Gavioli, Sanessa S. Griffiths, and Moderator – Zhanna A. Ziering.

In 2018, the IRS began to automatically assess civil penalties for the failure to file or to accurately file foreign international information returns, including but not limited to Forms 5471, 5472, 8865, 8938, 926, 3520, and 3520A. The mistakes that give rise to these failures are often very minor compared to the amount of the penalties assessed. Under current IRS procedures, the only pre-payment remedy is to rely on the IRS to exercise its discretion to abate the penalties based on reasonable cause. This panel will provide tips for navigating the penalty abatement process to help taxpayers avoid incurring significant penalties for relatively minor foot faults.