Tax Controversy: Significant Developments Your Firm Should Be Aware Of
As the Internal Revenue Service (IRS) heightens its enforcement activities, it is important that firms and their counsel stay updated with the new developments and must possess clear understanding of the methods and goals of the IRS. It is also essential to be prepared with an effective defense in the possibility of litigation.
This LIVE Webcast on Tax Controversy organized by The Knowledge Group brings together key thought leaders and expert practitioners to discuss significant topics on federal tax audits, appeals and litigation. This interactive course will provide crucial information on tax controversies including current enforcement initiatives, civil and criminal tax liabilities and other relevant issues.
In a two-hour live webcast, the speakers will cover:
- Emerging Trends in Tax Enforcement and Controversy
- New Partnership Audit Procedures
- Safe Harbors in Rev. Proc. 2016-40
- Civil and Criminal Liabilities
- Evolving Tax Court Procedural Developments
- Recent Changes to IRS Appeals Procedures
- Recent Tax Refund Litigation Updates
- Practical Tips to Consider
Norton Rose Fulbright US LLP
- Recent Changes to the IRS Examination and Appeals Processes.
- Privilege Claims have become a Major Area of Dispute.
- IRS Privilege Tactics in the Exam and Litigation Phases.
- The Use of Quick Peeks to Avoid Extended Motion Practice.
- IRS Use of Exam Authority to Circumvent Limited Discovery in Tax Court.
Culp Elliott & Carpenter P.L.L.C.
- Analysis of the 90 Day Letter: Jurisdictional and Burden of Proof Problems
- Preparation of the Petition
- Discovery in Tax Court under the “Branerton” Rule
- Preparation and Submission of Expert Witnesses under Rule 143(g)
- Standing Pre-Trial Order: Stipulations, Exchange of Documents and Pre-Trial Memos
- Trial Scheduling: Pre-Trial Conferences and Trial Dates Certain
- Opening Statements, Evidence, Witnesses and Trial
Who Should Attend:
- Tax Attorneys
- Enrolled Agents
- Tax Practitioners
- Internal Audits
- Tax Consultants
- Other Related/Interested Professionals
Chuck Hurley is a tax controversy lawyer and practices in Norton Rose Fulbright's Washington, DC office. Chuck has served as first chair on more than 20 jury and bench trials dealing with tax-related issues. His experience also includes IRS audits and appeals, tax consulting and planning, government relations, and IRS summons enforcement. Prior to entering private practice in tax controversy, Chuck spent more than 13 years' service (1990–2003) with the US Department of Justice's Tax Division, where he was responsible for preparing and conducting significant tax trials involving document-intensive, complex disputes. Chuck held first chair on two of the Tax Division's most prominent cases: Long-Term Capital Holdings v. United States and Trigon Insurance Co. v. United States.
Chuck Hurley is a tax controversy lawyer and practices in Norton Rose Fulbright's Washington, DC office. Chuck has served as …
Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott’s clients include Fortune 500 companies, entrepreneurial companies, estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel, and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics. Mr. Elliott also co-authored the nationally published treatise entitled Valuation Practice in Estate Planning and Litigation (Clark Boardman Callahan, 1994).
Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience …
Print and review course materials
Method of Presentation:
Experience in taxation
NASBA Field of Study:
Taxes - Technical
NY Category of CLE Credit:
Areas of Professional Practice
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About Norton Rose Fulbright US LLP
Norton Rose Fulbright is a global legal practice. They offer a full complement of tax law planning, regulation, investigation and litigation services to companies of all sizes, including many of the world’s largest financial institutions and corporations. They have more than 3800 lawyers, including 150 tax lawyers, based in over 50 cities across Europe, the United States, Canada, Latin America, Asia, Australia, Africa, the Middle East and Central Asia. Recognized for their industry focus, they are strong across all the key industry sectors: financial institutions; energy; infrastructure, mining and commodities; transport; technology and innovation; and life sciences and healthcare.
About Culp Elliott & Carpenter P.L.L.C.
Culp Elliott & Carpenter, PLLC is a Charlotte, North Carolina tax law firmfounded in 1982. It provides innovative tax, and legal solutions that create value for its clients, and helps clients achieve the most important goals in their businesses and lives. The Firm represents high-net-worth individuals, successful entrepreneurs, and corporate business clients. Firm members develop effective strategies to save on taxes, representing clients in the areas of estate planning, real estate and commercial transactions, mergers, acquisitions, restructuring and recapitalizations. Firm members handle civil and criminal tax litigation, and trusts and estates litigation, at all levels of dispute, and represent clients in disputes with the Internal Revenue Service. The Firm serves clients throughout the Southeastern United States.