26th Annual Tax Controversy Institute

Agenda

8:25 – 8:30 am

Opening Remarks

Charles Rettig, Institute Chair, Hochman, Salkin, Rettig, Toscher & Perez, P.C.

8:30 – 9:00 am
Current Priorities and Litigation Efforts in the Office of Internal Revenue Service
Chief Counsel

Featured Speaker:
Deborah Butler, Associate Chief Counsel (Procedure and Administration), Internal
Revenue Service, Washington D.C.

The Office of Chief Counsel is the chief legal advisor to the IRS Commissioner on the interpretation, administration and enforcement of the Internal Revenue Laws, and provides legal guidance and interpretive advice to the IRS, Treasury and to taxpayers.

Introduction:
David Rice, Law offices of David Lee Rice, APLC

9:00 - 9:30 am
Current Issues, Developments, and Priorities in the Office of IRS Appeals

Featured Speaker:
Kurt Meier, Senior Advisor to the Chief of Appeals, Chief, IRS National Office of Appeals, Washington, D.C.

Open discussion with Mr. Meier regarding current issues, developments, and priorities in the Office of IRS Appeals, including ongoing efforts to expedite the dispute resolution process. Appeals has primary responsibility for the administrative resolution of tax disputes. 

Introduction:
Steven Jensen

9:30 – 10:20 am
IRS Office of Professional Responsibility

Featured Speaker:
Karen L. Hawkins, Director, IRS Office of Professional Responsibility, Washington, D.C.

Ms. Hawkins’ presentation is followed by an open panel discussion regarding Cir 230 revisions, OPR monetary sanctions, representation of the practitioner who has an undeclared foreign financial account, contingent fees, practice pitfalls, conflicts, and related ethical issues.

Moderator and Panelist:
Dennis N. Brager, Brager Tax Law Group, APC

Panelists:
Karen L. Hawkins, Director, IRS Office of Professional Responsibility, Washington, D.C.
Erin M. Collins, Managing Director, Tax Controversy Services, KPMG, LLP
G. Michelle Ferreira, Greenberg Traurig, LLP

10:20 - 10:30 am
Break

10:30 - 11:20 am
Qualified Offers and the Recovery of Administrative and Litigation Costs from the IRS

This panel examines the procedure for the recovery of administrative and litigation costs by a taxpayer in federal tax controversies, and addresses the circumstances in which such costs are recoverable and the limitations on the recovery of such costs. The program also covers how to maximize the amount a taxpayer is entitled to recover, how to utilize the qualified offer provision of IRC §7430, the risk to the IRS and the litigation costs its required to pay during settlement negotiations.

Moderator and Panelist:
William Taggart, Taggart & Hawkins, Oakland, CA

Panelists:
Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams, &  Martin
Todd Welty, SNR Denton

11:20 am -12:10 pm
Administrative Techniques in a Recessionary Economy: CDP, IA, OIC, Innocent Spouse, and FOIA Requests

This panel discusses requests for Relief from Joint and Several Liability; strategies and selected current developments regarding IRS enforced collection efforts, offers in Compromise, Collection Due Process proceedings, and submission of a proper FOIA request as an administrative discovery tool.

Moderator and Panelist:
A. Lavar Taylor, Law Offices of A. Lavar Taylor

Panelists:
Claudia Hill, EA, Tax Mam, Inc./TMI Tax Services Group, Inc. and Editor-in-Chief, CCH Journal of Tax Practice & Procedure
William Davis, Kroney Morse Lan, PC
Steven L. Jager, CPA, Steven L. Jager, CPA, An Accountancy Corporation.

12:10 – 1:45 pm
Annual Bruce I. Hochman Award Luncheon

Award Recipient:
William Taggart, Taggart & Hawkins, Oakland, CA

Annual Chillin' & Grillin' Award

Introduction:
Steven Jensen

Luncheon Presentation
Chris Wagner, Commissioner, IRS Small Business / Self-Employed Division, Washington, D.C.

1:45 – 2:35 pm
Employment Tax Examinations and Investigations; Worker Classification Tools and Techniques

Roundtable panel discussion addresses classification of workers as independent contractors vs. employees, Section 530, IRS initiatives, audit programs, classification settlement program, and voluntary disclosures.

Moderator and Panelist:
Dennis L. Perez, Hochman, Salkin, Rettig, Toscher & Perez, PC.

Panelists:
Rick Raven, Deputy Chief, Criminal Investigation, IRS, Washington, D.C.
Chris Gaynor, CPA, Wayne, Gaynor & Umanoff, LLP
Igor Drabkin, Holtz, Slavett & Drabkin

2:35 – 2:45 pm
Break

2:45 - 3:45 pm
Representation Techniques: From Examination to Tax Court Litigation

This panel explores recent developments regarding civil penalties; understanding and defending an IRS Large Business & International Division “Wealth Squad” examination; pre-litigation and litigation practices, techniques, strategies, and alternatives; and possible taxpayer penalty defenses. What should you consider before, during, and after the administrative process? What may be discoverable and privileged?

Moderator and Panelist:
Michael Dolan, Director - Washington National Tax, KPMG, LLP

Panelists:
Deborah A. Butler, Associate Chief Counsel (Procedure and Administration), IRS Counsel, Washington, D.C.
Mark Hutchison, CPA, Rothstein Kass
Todd Welty, SNR Denton
 
3:45 - 5:00 pm
The Short Road between Civil and Criminal Tax Fraud

Don’t miss this enforcement update from the IRS Criminal Investigation Division and the Tax Division of the U.S. Attorneys Office (C.D. Cal.). When do Fraud Technical Advisors get involved in a civil examination? The panel discusses recent developments in the domestic and foreign voluntary disclosure practice of the IRS and the DoJ, and how to distinguish civil and criminal tax fraud.

Moderator and Panelist:
Steven Toscher, Hochman, Salkin, Rettig, Toscher & Perez, P.C. 

Panelists:
Victor Song, Chief, Criminal Investigation, IRS, Washington, D.C.
Sandra Brown, Chief, Tax Division, United States Attorney’s Office (C.D. Cal.)
John Rossmiller, Territory Manager, Fraud/BSA, SBSE
Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams, and Martin
Elliott Kajan, Kajan, Mather & Barish
Martin Schainbaum, Martin A. Schainbaum, APC

5:00 pm
Reception