Handling a Tax Controversy: Audit, Appeals, Litigation, and Collections. Annual Course/Video Webcast. Thursday-Friday, October 16-17, 2014

Transcription

1 Annual Course/Video Webcast Register today to learn practical solutions, get valuable insights, have your most pressing questions answered, and meet sophisticated colleagues from across the country. Handling a Tax Controversy: Audit, Appeals, Litigation, and Collections Thursday-Friday, October 16-17, 2014 Washington, DC (Liaison Capitol Hill Hotel) and Live Video Webcast Register online: CLE credit hours, including one hour of ethics 16.5 CPE credit hours in Taxation This go-to program has become the relied-upon and trusted tool for tax practitioners handling federal tax controversies. The outstanding faculty provides insights and practical pointers on all aspects of dealing with the government in a tax dispute, including: the latest developments in federal tax controversies new trends in preparing for audits and administrative appeals navigating the complexity of international disclosure and filing requirements, limitations and settlement opportunities strategies for litigating contested tax disputes and best practices for defending against federal tax collections and other options to consider Join us in, and come away equipped with the latest information and strategies to meet the demands of your tax practice.

2 Planning Chairs (also on faculty) Caroline D. Ciraolo Rosenberg, Martin, Greenberg, LLP, Baltimore Gerald A. Kafka Latham & Watkins LLP, Brian C. McManus Latham & Watkins LLP, Faculty Frank Agostino Agostino & Associates, P.C., Hackensack, New Jersey Jennifer Best Senior Attorney-Advisor, Services and Enforcement, Internal Revenue Service, * Megan L. Brackney Kostelanetz & Fink, LLP, New York Larry A. Campagna Chamberlain, Hrdlicka, White, Williams & Aughtry, LLP, Houston Nathan E. Clukey King & Spalding, Michael J. Desmond The Law Offices of Michael J. Desmond, APC, Santa Barbara, California Miriam L. Fisher Latham & Watkins, LLP, Thomas Greenaway Managing Director, KPMG LLP, Boston David Gustafson Judge, U.S. Tax Court, Karen Hawkins Director of the Office of Professional Responsibility, Internal Revenue Service, Jenny L. Johnson Holland & Knight LLP, Chicago Paula M. Junghans Zuckerman Spaeder LLP, Sheldon M. Kay Sutherland, Asbill & Brennan LLP, Atlanta Kevin L. Kenworthy Miller & Chevalier Chartered, Kathleen Kerrigan Judge, U.S. Tax Court, Albert Lauber Judge, U.S. Tax Court, Mark E. Matthews Caplin & Drysdale, Chartered, Fred F. Murray Managing Director, Grant Thornton LLP, Peter J. Panuthos Chief Special Trial Judge, U.S. Tax Court, Wm. Robert Pope, Jr. White & Reasor, Nashville, Tennessee Charles P. Rettig Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, California Christopher Rizek Caplin & Drysdale, Chartered, William E. Taggart, Jr. Law Offices of William E. Taggart, Jr., Oakland, California Juan F. Vasquez, Jr. Chamberlain, Hrdlicka, White, Williams & Aughtry, LLP, Houston Diana Wollman Director, International Strategy, Internal Revenue Service, * ALI CLE Program Attorney: Jaimee Taibi (jtaibi@ali-cle.org) *Invited Additional Internal Revenue Service speakers and judges to be announced.

3 Program All times Eastern Time Thursday, October 16, :30 a.m. Registration and Continental Breakfast 8:25 a.m. Administrative Remarks VIDEO WEBCAST SEGMENT A 8:30 a.m. Audits: Types of Audit, Audit Techniques and Procedures Ms. Brackney and Mr. Rettig 9:15 a.m. Information Gathering for Audits: IDRs, Summonses, and Third-Party Information Mr. Murray and Ms. Johnson 10:15 a.m. Networking and Refreshment Break 10:30 a.m. Audits: International Compliance Issues and Penalties Mss. Best* and Wollman* and Mr. Matthews 11:30 a.m. Audits: Claims for Relief from Joint and Several Liability Ms. Ciraolo and Mr. Taggart 12:15 p.m. Question and Answers 12:30 p.m. Networking Lunch Sponsored by Latham & Watkins LLP and Rosenberg, Martin, Greenberg, LLP VIDEO WEBCAST SEGMENT B 2:00 p.m. Audits: Statutes of Limitations, Qualified Offers, and Closing Documents Messrs. Greenaway and Vasquez 2:45 p.m. Networking and Refreshment Break 3:00 p.m. Appeals and Administrative Alternative Dispute Resolution Messrs. Campagna and Kay 4:15 p.m. Administrative Collection Procedures: Collection Alternatives and Appeals Messrs. Agostino and Pope 5:30 p.m. Questions and Answers 5:45 p.m. Adjournment for the Day ALI CLE Curriculum Business / Corporate Law and Taxation Renowned for their sophistication and relevancy, ALI CLE s business organizations, corporate law, and taxation courses provide the information practitioners need to know in order to excel in these ever-evolving areas of law. Learn from high-caliber ALI CLE faculty, comprised of top law firm and corporate counsel, regulators, federal bench members, and experts from tax, audit, consulting, and other service industries. Popular courses offer comprehensive coverage of a wide variety of matters, including corporate taxation, cyber security risks for financial institutions, mergers and acquisitions, partnerships, buy-sell agreements, and charitable planning.

4 Friday, October 17, :00 a.m. Continental Breakfast and Networking Session VIDEO WEBCAST SEGMENT C 8:30 a.m. Choice of Forum Messrs. Greenaway, Kafka, and Kenworthy, and Judge Gustafson 9:15 a.m. Tax Court Procedures: Commencement of a Deficiency Proceeding and Pretrial Practice (Informal and Formal Discovery) Mr. Desmond and Judge Panuthos 10:15 a.m. Networking and Refreshment Break 10:30 a.m. Tax Court Procedures: Pretrial Practices (Motions, Pretrial Memoranda, Stipulations of Fact, Exhibits, and Witness Subpoenas) Judge Kerrigan, additional speakers to be announced. 11:30 a.m. Questions and Answers 11:45 a.m. Networking Lunch Sponsored by Latham & Watkins LLP and Rosenberg, Martin, Greenberg, LLP VIDEO WEBCAST SEGMENT D 1:15 p.m. Tax Court Procedures: Trial, Briefing, and Decisions Ms. Fisher and Mr. Rizek, and Judge Lauber 2:30 p.m. Networking and Refreshment Break 2:45 p.m. Refund Litigation (and Other Proceedings) in the U.S. District Courts, U.S. Court of Federal Claims Messrs. Clukey and McManus, additional U.S. Department of Justice speaker to be announced. 3:45 p.m. Ethics: Navigating the Eggshell Audit and Tax Litigation Mss. Ciraolo, Hawkins, and Junghans Here s what registrants have said about recent presentations of this course: All topics were excellent and on point! You have a great balance of presenters, private practice, IRS/DOJ, and judges. I was extremely impressed and satisfied with the breadth and scope of the topics and the quality and credentials of the panelists. Bottom line great presentations and well worth attending. Thanks!

5 4:45 p.m. Questions and Answers 5:00 p.m. Adjournment *Invited at the time of printing. Total 60-minute hours of instruction: 13.75, including 1 hour of ethics 16.5 CPE credit hours in Taxation (live group and group-internet-based program) ALSO FROM ALI CLE... Employee Benefit Plans of Tax-Exempt and Governmental Employers September 11-12, 2014 Washington, DC or Live Video Webcast Accountants Liability 2014: Confronting Enforcement and Litigation Risks September 11-12, 2014 Washington, DC or Live Video Webcast On location: Maximize your CLE experience. Learn from the best and network with other serious practitioners. Register one person from your firm for this course and get all subsequent registrations at 50% off. UP TO 50% OFF from ALI CLE superb instruction and practical advice available in multiple formats providing numerous ways to further your knowledge while satisfying your CLE requirements Webcast: Can t attend on location? Register for the live webcast and participate by asking questions online, in real time, and get our famous course materials via searchable PDF. Interrupt the program at any time and catch up later with the free online archive. Get all the information you need, and satisfy your CLE needs, without leaving your office. $1,099 Group Webcast: Schedule a convenient group viewing of this course for two or more people and save on tuition. Provide your firm or department with access to the finest legal talent and train more people at a lower cost without the additional expense or time constraints of travel. UP TO 30% OFF On-demand CLE: Online audio and searchable (PDF) course materials are available 24/7 for every course and course segment. Free To Registrants DVD / CD-ROM / Audio MP3 Listen to ALI CLE s renowned courses in your car, home, or office on your computer, DVD player, or MP3 player at your own pace. $899 / 699 Print + Digital Course Materials ALI CLE s acclaimed course materials are available in print or electronically and can be purchased before or after the course. $149

6 HOW TO REGISTER online phone CLE NEWS fax mail return the form on the back panel of this brochure to: REGISTRAR, ALI CLE, 4025 Chestnut Street, Philadelphia, PA GET MANDATORY CLE AND CPE CREDIT Virtually all ALI CLE programs receive CLE credit in AK, AL, AR, AZ, CA, CO, DE, FL, GA, HI, IA, IL, IN, KS, KY, LA, ME, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, PA, RI, SC, TN, TX, UT, VA, VT, WA, WI, and WV. Upon request, ALI-CLE will apply for CLE credit in ID, OR, and WY. This course is expected to qualify for credits, including 1 ethics credits, in 60-minute MCLE jurisdictions; and for 16.5 credits, including 1.2 ethics credits, in 50-minute MCLE jurisdictions. In NY, the in-person course is appropriate for both newly admitted and experienced attorneys. For specific information on CLE, CPE, or other professional accreditation in your state, please the MCLE Team at TeamMCLE@ali-cle.org, go to org/mcle, or call CLE-NEWS. NASBA ALI CLE is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors through its website: For more information regarding ALI CLE s administrative policies, such as complaint and refund, please call Customer Service at (800) CLE- NEWS. CPE credit hours for this course: 16.5 in Business Law (live group and group-internet-based program). Learning Objectives: Acquisition of knowledge and skills to develop proficiency as a practitioner; maintenance of professional competence as a practitioner; provision of information on recent legal developments. Suggested Prerequisite: Limited experience in legal practice in subject matter or completion of Basic CLE course in subject matter. Level of Instruction: Intermediate HOTEL ACCOMMODATIONS A limited block of rooms has been reserved at the Liaison Capitol Hill. Room rate: $234 per night, single or double occupancy (additional person charge after that is $20 per night). These rooms will be held as a block, unless exhausted, until October 1, 2014, at which time they will be released to the general public. Registrants must make their own hotel reservations and indicate that they are part of the American Law Institute (ALI) group to guarantee the group rate. Room reservations may be made by calling the Liaison Capitol Hill, 415 New Jersey Avenue, NW, Washington, DC or ( ); or ing reservations@affinia.com. Confirmations will be sent by the hotel. Please read the cancellation policy carefully. Go to for more info about: registration/cancellation/requirements for persons with disabilities/scholarships FOLLOW US ON: Facebook: facebook.com/morethancle Visit our Blog: Morethancle.org Catch the fever. Create a buzz with social networking. Tweet today and interact with other course registrants and faculty. Consider posting new course topics and pose questions you have for the faculty. Or simply use this social networking tool to make lunch or dinners plans with others in attendance. #HTC2014

7 Handling a Tax Controversy: Audit, Appeals, Litigation, and Collections Register online: Handling a federal tax controversy requires balancing risks and applying sophisticated skills. Tax practitioners must employ both for their clients and this program will show you how! This comprehensive program addresses the practical aspects of handling and resolving a tax dispute with the federal government. A prestigious faculty of private practitioners, senior government officials, and judges examines the complete life cycle of a federal tax controversy, from audit to appeal to litigation. Along the way, consideration is given to key issues such as forum selection, the influence of new case law, assessments, and collection efforts. Join us for a thorough discussion of the most critical issues in your federal tax practice, including: audit techniques, procedures, and dealing with sensitive issues at an audit properly calculating and knowing when to extend limitations best practices for handling administrative appeals attorneys fees, ADR, and forum considerations Tax Court rules and procedures Collection strategies, appeals, and alternatives WHO SHOULD ATTEND This program will benefit tax practitioners who want to enhance their existing skills in handling tax controversies; tax practitioners who want to learn about the tax controversy process in order to become better-informed tax planners; and lawyers who want to add tax controversy representation to their practice repertoire. Outstanding, diverse and approachable group of talented, knowledgeable speakers. Excellent course. Syllabus with practical practice tips. previous attendee

8 American Law Institute Continuing Legal Education 4025 Chestnut Street, Philadelphia, PA NONPROFIT ORG U.S. Postage PAID ALI CLE KEY CODE CW015LM Name Title Firm Address City State Zip printed on FSC certified paper Online Phone CLE NEWS FAX Mail Registrar, ALI CLE, 4025 Chestnut Street, Philadelphia, PA Handling a Tax Controversy: Audit, Appeals, Litigation, and Collections Washington, DC, October 16-17, 2014 $1,399 Please enter registration(s): $1,399 CW015 Please provide my course materials as a (choose only one): USB drive Printed course book Please go green and order your study materials on a USB drive. To register additional on-location registrants at 5 0 %o ff, call 800-CLE-NEWS ( ). Video Webcast $1,099 / $329 Full program. Tuition: $1,099 WAW015 Webcast Segment C: $329 WAW015C Webcast Segment A: $329 WAW015A Webcast Segment D: $329 WAW015D Webcast Segment B: $329 WAW015B Can t attend? You don t have to miss anything! Order the: DVD (video), including a complimentary MP3 CD-ROM and PDFs of the course materials $899 AW015V Audio MP3 CD-ROM (including PDFs of the course materials) $699 AW015 Printed course materials only $149 SW015 Partial Scholarships Scholarships covering 30% of tuition fees, valid for on-site courses, live webcasts, and webcast segments only, are available. Scholarships cannot be combined with other offers. I am a full-time employee of the federal, a state, or a local government or governmental agency. I am a recent law school graduate (<5 years). I am a retired senior lawyer (65 or older). $ Total Check enclosed (payable to ALI CLE) Please charge to my credit card: AMEX DISCOVER MasterCard VISA Card no.: Card expiration date: / SIGNATURE ADDRESS (REQUIRED FOR WEBCASTS AND ONLINE SUBSCRIPTIONS) CW015