2:00pm   Opening Remarks by the Chair.

2:10pm   Proposed Amendments to Non-Tax Shelter Ethics Standards in Circular 230.  New amendments are expected to be issued before the Midyear meeting on the following important issues: 1) Further clarification on when contingency fees are available; 2) Public disclosure of disciplinary proceedings; 3) New discovery rules during disciplinary proceedings (protective orders, timing, etc.) and 4) Monetary and other penalties, including censure. It is anticipated that the Service will request comments and feedback. The panelists will discuss each of these amendments. Moderator: Nancy Chassman, Ernst & Young LLP, New York, NY. Panelists: Deborah Butler, Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC; Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Martin, Houston, TX.

2:40pm   You Say Yes, I Say No, No, No – Ethics Considerations When The Client Fails To Follow Counsel''s Advice.   In numerous situations in tax investigations or examinations, we give advice to our clients concerning entering into transactions, filing returns, and taking reporting positions.  On most occasions, the client follows our advice, sometimes reluctantly.  This panel will examine the applicable ethical standards for a practitioner when the client refuses to follow legal advice.  With the enhanced enforcement focus on the relationship between tax practitioners and their clients, the panel will explore whether counsel''s ethical obligations cease upon the mere delivery of advice to the client, or whether counsel must follow through and react upon a client''s failure to follow it.  Moderator:  Scott D. Michel, Caplin & Drysdale, Washington, DC.  Panelists: Professor Michael Lang, Chapman University Law School, Orange, CA; Harvey M. Silets, Katten Muchin Rosenman LLP, Chicago, IL.
 
3:30pm   Ethics Considerations Under Section 7525:  What Remains Of The Federally Authorized Tax Practitioner Privilege?  This panel will explore how the federally-authorized tax practitioner privilege has developed in recent years.  Panelists will address whether it has any strength in the wake of newly-revised Sections 6111, 6112 and 6708 and recent cases. Moderator: Danielle Smith, White & Case LLP, New York, NY.  Panelists: Allan H. Cohen, Arthur Andersen LLP, city, state; Michael Desmond, Tax Legislative Counsel, US Department of Treasury, Washington, DC; Lance E. Rothenberg, Fulbright & Jaworski LLP, New York, NY; Drita Tonuzi, Deputy Division Counsel, Office of the Division Counsel (Large and Mid-Size Business), IRS, Washington, DC. 

All three panel programs should qualify for ethics credit, and should be of interest to young lawyers.