|
Thursday, October 19
6:30PM - 9:30PM
Administrative Practice Dinner (Invitation Only)
Friday, October 20
8:30AM - 11:30AM
Administrative Practice Committee
Chair: Thomas J. Callahan, Thompson Hine LLP, Cleveland, OH
8:30am Opening Remarks by the Chair.
8:35am Important Developments. This panel will discuss
important developments in administrative which
have occurred since the last meeting. Moderator:
Jamie Hartford, Ernst & Young LLP, Washington, DC.
Panelists: Kevin Johnson, Miller & Chevalier Chartered,
Philadephia, PA; Brian C. Bernhardt, McGuireWoods
LLP, Richmond, VA; Deborah A. Butler, Associate
Chief Counsel (Procedure & Administration), IRS,
Washington, DC.
9:05am Ethical Issues Before Tax Litigation. (Part 1 of 2
– 2nd Part in Court Procedure and Practice Committee
Meeting). This panel will discuss ethical concerns
during the administrative stages of a tax controversy.
Topics to be discussed will include the obligation to
retain electronic documents; conflicts of interest;
powers of attorney; and summons procedures. The
discussion will address the ABA Model Rules of
Professional Responsibility, including Model Rules
1.9, 1.11, and 4.2. Moderators: Jeffry J. Erney,
Thompson Hine LLP, Cleveland, OH; Carol A.
Szczepanik, Senior Attorney, Office of Chief Counsel,
IRS, Cleveland, OH. Panelists: Jennifer Breen,
Attorney (Procedure & Administration), Office of
Chief Counsel, IRS, Washington, DC; David F.
Axelrod, Deloitte Financial Advisory Services LLP,
Columbus, OH.
9:55am Appeals Mediation. This panel will focus on using
mediation as a case settlement technique at the
Appeals Division. Post Appeals mediation options
will also be discussed. Moderator: Maxine Aaronson,
Law Offices of Maxine Aaronson, Dallas, TX.
Panelists: Sarah H. Ingram, Chief of Appeals, Office of
Appeals, IRS, Washington, DC; M. Carr-Ferguson,
Davis Polk & Wardwell, New York, NY; Steven C.
Salch, Fullbright Jaworski LLP, Houston, TX.
10:45am Collection Due Process: The Increasing
Importance of Administrative Record.
Co-Sponsored by: Low Income Taxpayers
Committee (Tax) This panel will highlight the caselaw
and the changes in the regulations as well as some
practical issues on making the record. Moderator:
Elizabeth J. Atkinson, Kaufmann & Canoles, Norfolk, VA.
Panelists: Robert A. Wherry Jr., Judge,
United States Tax Court, Washington, DC; Professor
Jerry Borison, University of Denver, Denver, CO;
Professor Diane Fahey, New York Law School, New
York, NY.
Saturday, October 21
7:00AM – 9:00AM
Low Income Taxpayers & Administrative Practice
Low Income Taxpayers Chair: Elizabeth Atkinson, Kaufman & Canoles, Norfolk, VA
Administrative Practice Chair: Thomas J. Callahan, Thompson Hine LLP, Cleveland, OH
7:00am Opening Remarks by the Chair.
7:05am Recent Developments Affecting Low Income
Taxpayers. The speaker will update the committee
on new developments, emphasizing those that
impact low income taxpayers. Speaker: Carol
Nachman, Special Counsel, Administrative
Provisions and Judicial Practice (Procedure and
Administration), Office of Chief Counsel, IRS,
Washington, DC.
7:20am Collection Due Process Smorgasbord. This panel will discuss the collection due process procedure. What issues may the taxpayer raise? Is CDP available to review innocent spouse cases involving underpayments only? What is the government’s obligation to suggest collection alternatives? How do the new rules for offers in compromise affect the CDP process? The new/proposed regulations governing CDP will be discussed as well as court decisions affecting CDP. Moderator: Dale Kensinger, Kansas City Tax Clinic, University of Missouri School of Law, Kansas City, MO. Panelists: Matthew Weir, Attorney-Advisor to National Taxpayer Advocate, IRS, Baltimore, MD; Professor Keith Blair, University of Baltimore School of Law, Baltimore, MD.
8:45am Appeals and Low Income Taxpayers. Speaker: Sarah Hall Ingram, Chief of Appeals, Office of Appeals, IRS, Washington, DC.
|
