2:30pm   Opening Remarks by Chair.

2:35pm   Remarks on Behalf of the Tax Court.  Speaker: The Honorable Joel Gerber, Chief Judge, United States Tax Court, Washington, DC.

2:50pm   FAS 109 and the Continued Erosion of Privilege.  The standards for reporting uncertain tax positions under FAS 109 were recently changed.  This panel will discuss those changes and their relevance to tax controversy lawyers, including implications for attorney-client privilege and business that FAS 109 may generate for tax litigators.  Moderator: Peter A. Lowy, Shell Oil Company, Houston, TX.  Panelists: Robin L. Greenhouse, McDermott Will & Emery LLP, Washington, DC; Cary D. Pugh, Skadden Arps Slate Meagher & Flom LLP, Washington, DC; Kathryn A. Zuba, Special Counsel (Procedure and Administration), Chief Counsel, IRS, Washington, DC.

3:25pm   Remarks on Behalf of the Office of Chief Counsel, Internal Revenue Service.  Speaker: Deborah A. Butler, Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC. 

3:40pm   Recent Developments and Trends in Tax Shelter Litigation in the Court of Federal Claims and District Courts.  This panel will discuss recent developments and trends in tax shelter refund litigation.  The panelists will focus on the cases currently docketed across the country, the transactions at issue, and certain procedural issues raised in these cases.  Moderator: Charles M. Ruchelman, Dewey Ballantine LLP, Washington, D.C.  Panelists:  David Gustafson, Chief of the Court of Federal Claims Trial Section, Department of Justice, Tax Division, Washington, DC; Henry S. Schneiderman, Special Counsel, Office of the Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Lawrence M. Hill, Dewey Ballantine LLP, New York, NY.

4:25pm   Spotlight on Procedure: The Mailbox Rule.  Moderator: Christopher Pietruszkiewicz, Paul M. Hebert Law Center, Louisiana State University, Baton Rouge, LA.

4:35pm   Publicity in Litigated Tax Cases.  Press coverage increasingly accompanies litigated tax cases.  This panel will discuss strategies for managing publicity in such cases, taxpayer concerns, the role of the public relations specialist, and the viewpoint of the press.  Moderator: Thomas Cullinan, Sutherland Asbill & Brennan LLP, Atlanta, GA.  Panelists: Lee Sheppard, Contributing Editor, Tax Analysts, Falls Church, VA; Don Lancaster, United Parcel Service, Atlanta, GA; Richard Levick, President, Levick Strategic Communications LLC, Washington, DC.

5:20pm   Current Developments.  Speaker: Juan F. Vasquez Jr., Chamberlain Hdrlicka White Williams & Martin, Houston, TX.