Navigating Federal Tax Litigation and Appeals: Recent Cases, Administrative Processes, Strategies for Counsel
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax counsel and advisers guidance on the best practices to resolve federal tax controversies. The panelists also discuss the impact of recent tax cases, navigating administrative appeals procedures, and recent IRS enforcement initiatives. The panelists will also discuss key considerations in resolving tax controversies and offer practical tips in light of recent court cases, potential changes under the new administration, pitfalls to avoid, and other vital items.
Outline
- Overview of the tax controversy process
- Best practices to resolve tax controversies involving the IRS
- Compliance and resolution options, including the various programs to voluntarily come into compliance
- The current enforcement landscape, including as a result of clawbacks of funding under the Inflation Reduction Act of 2022 and executive orders to reduce the federal workforce
- Current developments, including recent tax cases and administrative developments affecting controversies involving the IRS
Benefits
The panel will discuss these and other key issues:
- Navigating the administrative and judicial tax controversy process
- What are the critical challenges of tax controversies, administrative appeals, the district court, and tax court?
- What compliance and resolution options are available prior to and during tax proceedings?
- Navigating potential penalties and designing defense strategies
- What is the impact of recent court cases on tax audits, examinations, administrative appeals, investigations, and litigation?
Faculty
Jeffrey M. Glassman
Partner
Meadows, Collier, Reed, Cousins, Crouch & Ungerman
Mr. Glassman is a firm partner with a practice focus that includes counseling individuals, businesses, and trusts and... | Read More
Mr. Glassman is a firm partner with a practice focus that includes counseling individuals, businesses, and trusts and estates with respect to their most demanding tax planning and controversy issues. His tax controversy practice involves representing clients in all stages of civil and criminal tax matters, including complex IRS examinations, administrative appeals, ruling requests, payroll tax disputes, federal tax collection issues, government investigations, and litigation. Mr. Glassman works with clients in developing strategies to resolve sensitive compliance issues such as unreported income and undeclared offshore accounts and assets. He also advises individuals regarding emerging technology tax issues related to cryptocurrencies, non-fungible tokens, and other digital assets. Recently, Mr. Glassman has focused significant time on tax disputes involving private aircraft and employee retention credit matters (ERC), including ERC refund lawsuits against the federal government. The vast majority of his cases are resolved privately and never made public.
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Lawrence A. (Larry) Sannicandro
Partner
Pillsbury Winthrop Shaw Pittman
Mr. Sannicandro focuses his practice on a broad range of federal and state tax disputes affecting individual... | Read More
Mr. Sannicandro focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses (both public and private). These disputes cover the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, litigation before the United States Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts and state tax tribunals. Mr. Sannicandro has favorably resolved hundreds of tax disputes involving income taxes, estate and gift taxes, employment and payroll taxes, excise taxes, sales and use taxes, federal and state tax credits, and employee plan matters. Drawing on his background as a former estate and gift tax attorney for the IRS, he is uniquely well-versed in estate and gift tax planning techniques, the valuation of closely held businesses, and defending those planning and valuation techniques in disputes with tax authorities. Mr. Sannicandro also works with clients to provide substantive legal advice on uncertain tax positions, identify and quantify tax-based risks, and proactively manage those risks through various procedural strategies.
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Cannot Attend March 18?
Early Discount (through 02/21/25)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.