• 2022 IRS Representation Conference
    • Schedule
    • Speakers
    • Sponsors
    • Continuing Education
    • Register for WEBCAST
    • IN-PERSON FULL
  • 2022 Criminal Tax Day
    • Schedule
    • Speakers
    • Sponsors
    • Continuing Education

REGISTER TODAY!

hello@taxrepllc.com
$0.00
No products in the cart
Go to shop
Login

Login
IRS Representation ConferenceIRS Representation Conference
IRS Representation ConferenceIRS Representation Conference
  • 2022 IRS Representation Conference
    • Schedule
    • Speakers
    • Sponsors
    • Continuing Education
    • Register for WEBCAST
    • IN-PERSON FULL
  • 2022 Criminal Tax Day
    • Schedule
    • Speakers
    • Sponsors
    • Continuing Education

Thursday Workshop

SCHEDULE

November 17, 2022 | Quinnipiac University School of Law

All Times are EASTERN

All times are EASTERN

9:30 – 10:15 am:

Registration

10:15 – 10:30 am:

Opening Remarks / Housekeeping Items

10:30 – 12:00 pm:

Straight Talk on Security Six: What Every Tax Pro Must Consider

As the busy year end and tax season approaches, it’s critical to ensure you are taking all possible precautions to secure your firm, protect your clients’ data, and stay in compliance with IRS guidelines and regulations for tax and accounting professionals.  

Attend this special panel discussion to hear directly from the IRS about what the implementation of the “Security Six” recommendations should really look like in your firm and to learn about the cornerstones of creating a plan to satisfy the FTC’s Safeguard Rule for PTIN holders.

Moderator:

  • Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:

  • Margaret Romaniello, Senior Stakeholder Liaison, IRS, Hartford, CT
  • Joseph McCarthy, Senior Stakeholder Liaison, IRS, Hartford, CT
  • Paul Greenberg, CPA, Ritch, Greenberg & Hassan, CPAs, Shelton, CT

12:00 – 1:00 pm:

Lunch

1:00 – 2:00 pm:

The IRS Exam: Who Should Deal with the Revenue Agent?

So, the exam notice arrived and the client is very concerned. As the return preparer this is not a problem, just gather the records and handle the exam, right? What if it’s not so routine…. “you see, a bunch of those expenses…well they might have been made up…and lets not bring up the cash that did not make it into the POS system…” Our panel of experts will review how to handle the routine and not-so-routine exam and what role each person should play: the original preparer, the dummy accountant, the Kovel accountant, and the criminal tax attorney.

Moderator:

  • Sara V. Spodick, Esq., Quinnipiac University Law School, North Haven, CT

Panelists:

  • Fran Obeid, Esq., MFO Law PC, New York, NY
  • Walter Pagano, CPA, CFE, Eisner Advisory Group LLC, New York, NY
  • Richard J. Sapinski, Esq., Sills Cummis & Gross, P.C., Newark, NJ.

2:00 – 3:00 pm:

Challenging Tax Penalties

Those late-night commercials make it sound just so easy, but how do you get rid of tax penalties?  This program will cover many of the frequently assessed civil penalties and additions to tax assessed by the IRS, and the various grounds upon which practitioners seek abatement.  The program will cover administrative waivers (referred to as “First Time Abatement”), the defenses of reasonable cause and substantial compliance, and best practices to avoid penalties during the audit. The program will cover IRS Account Transcript analysis to determine if First Time Abatement applies, strategies for documenting your client’s case for reasonable cause, and preparing and taking an initial denial of penalty abatement to IRS Appeals.

Moderator:   

  • Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:   

  • Michael Sardar, Esq., Kostelanetz & Fink, LLP, New York, NY
  • Beverly L. Winsted, Esq., Law Office of Beverly Winsted,  Laurel, MD
  • Roger Nemeth, EA, Tax Help Software, Tallahassee, FL

3:00 – 3:15 pm:

Break

3:15 – 5:00 pm:

US Tax Court: Considering Supervisory Approval and Reasonable Cause

Join us for a front row seat to observe a taxpayer and their representative challenge civil tax penalties in the United States Tax Court on the grounds that the IRS failed to properly approve the penalties under IRC 6751(b) and, in the alternative, that the taxpayer acted with reasonable cause. After the hearing, you will hear from the judge as she addresses the arguments raised and renders a decision. Finally, our panelists will conduct a debrief with the audience, discussing best practices.

Taxpayer’s Attorney: 

  • Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ

Taxpayer: 

  • Caren Zahn, EA, Agostino & Associates, Hackensack, NJ

Government Attorney:

  • William Bogardus, Office of Chief Counsel, Internal revenue Service, Boston, MA

IRS Examiner:

  • Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA

Judge: 

  • Honorable Diana Leyden, United States Tax Court, Washington, DC

Friday IRS Representation Conference

SCHEDULE

November 18, 2022 | Omni Hotel New Haven, CT

All Times are EASTERN

Schedule: Friday, November 18, 2022

7:30 – 8:30 am:

Breakfast / Registration

8:30 – 8:35 am:

Opening Remarks / Housekeeping Items

8:35 – 10:00 am:

IRS Update

Hear directly from the IRS Executives what to expect from the IRS this coming year.

SB/SE Update:

  • SB/SE Commissioner Amalia C. Colbert
  • Interviewed by Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT

Independent Office of Appeals Update:                              

  • Andy Keyso, Chief of Appeals
  • Interviewed by G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

National Taxpayer Advocate Update:          

  • Kristy Moquin, Deputy National Taxpayer Advocate, IRS, Hartford, CT
  • Interviewed by Lisa E. Perkins, Esq., Green & Sklarz LLC, West Hartford, CT

10:00 – 10:10 am:

Break

10:10 – 11:00 am:

Enforcement Trends: Crypto, Conservation Easements, Micro-captives, Marijuana – What’s Hot and What’s Not!

Our panel will review the current trends in IRS enforcement, discuss the IRS Dirty Dozen and latest LB&I Campaigns, and what to expect in the coming year.

Moderator:   

  • Guinevere M. Moore, Esq., Moore Tax Law Group, LLC, Chicago, IL

Panelists:   

  • Daniel Mayo, Esq., Withum, Smith & Brown, PC, Red Bank, NJ
  • Victor A. Jaramillo, Esq., Caplin & Drysdale, Washington, DC
  • Richard Tierney, Deputy Director of Exam, Internal Revenue Service, Boston, MA

11:00 – 12:00 pm:

Ethics: The Ethical Issues Around Whistleblowing: Can We or Can’t We?

According to the Commissioner, our nation’s tax gap is approximately $1 trillion. While a portion of the gap is attributable to taxpayers who are simply unable to pay tax due and owing, much of the gap is the result of intentional conduct – abusive transactions, false returns, evasion of assessment, evasion of payment, and other knowing violations. What can you do if your client knows about tax crimes being committed under their watch? They can strike a blow for justice, help the American tax system, and get paid to do it. Nothing more American than that!  But what if the target is a client?  Can we ethically blow the whistle on a client, former client, potential client, or related third parties?  Our panel of experts will review the whistleblower program and discuss the various ethical issues surrounding both representing the whistleblower as well as becoming a whistleblower yourself, and what you can and cannot do.

Moderator:     

  • Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:

  • Walter Pagano, CPA, CFE, Eisner Advisory Group LLC, New York, NY
  • Karen L. Hawkins, Esq., Attorney-At-Law, Yachats, OR

12:00 – 12:45 pm:

Lunch

FOLLOWING THE LUNCH BREAK, WEBCAST ATTENDEES WILL HAVE ACCESS TO TRACK A

12:45 –1:45 pm:

Track A: The Tax and Non-Tax Pitfalls of Liquidating the Business

Remember that new business venture where everyone was ready to launch the next Amazon?  Guess what?  Things did not go quite as well as they had hoped, and now the business, business relationships, and even their own financial plans are quickly dissolving into a mess and the closing of the business.  Our panel will discuss the various tax and non-tax issues clients will need to face when the business breaks up and how practitioners can help their clients navigate the situation and avoid it becoming more of a mess than it already is.

Moderator:     

  • Jason A. Marsh, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:  

  • Robert Turnipseed, Esq., Ambrecht Jackson LLP, Mobile, AL
  • Robert M. Finkel, Esq. Moritt Hock & Hamroff LLP, New York, NY

Track B: Estate & Gift Update Part 1: IRS Challenges to Your Client’s Best-Laid Plans

SLATs, GRATs, IDGTs and ILITs.  Terrific planning techniques that, when set up and managed correctly, can save millions of dollars in estate taxes and transfer the family business and wealth to the next generation.  What happens when the IRS and/or state tax authorities show up and disagree? Our panel will review issues surrounding the most popular estate planning techniques and what practitioners should look for when clients decide to get their “financial house” in order and do their planning, and what to do when the letter from Uncle Sam arrives to review the planning.

Moderator:  

  • Lawrence A. Sannicandro, Esq., McCarter & English, LLP, Newark, NJ

Panelists:  

  • Kristen M. Lynn, Esq., Green & Sklarz LLC, New Haven, CT
  • Anthony F. Vitiello, Esq., Connell Foley, Roseland, NJ
  • Barry Fischman, CPA, Marcum LLP, New Haven, CT

1:45 – 2:45 pm:

Track A: From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime

Audits of partnerships were previously governed by special procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). Starting with tax year beginning January 2018, partnership audits are governed by the new Centralized Partnership Audit Regime. The new regime is dramatically changing the way audits are handled and practitioners must understand the new rules to effectively represent their clients and avoid costly mistakes. This panel will discuss the differences between TEFRA and the BBA, and preparing for and effectively manage a partnership audit under the new rules.

Moderator: 

  • Caroline D. Ciraolo, Esq., Kostelanetz & Fink, LLP, Washington, DC

Panelists: 

  • Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA
  • Steven Hurok, Esq., Citrin Cooperman & Company LLP, New York, NY
  • G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

Track B: Estate & Gift Update Part 2: Pitfalls When Handling the Estate and Why the Tax Returns Matter!

Hidden offshore bank accounts, a second set of books, unreported taxable gifts, and fraudulent income tax returns. Pitfalls for the unwary practitioner attempting to assist clients with probating their loved-one’s estate.  This program will cover the key issues that need to be addressed, the questions that should be raised, and best practices in remediating past misdeeds.  The program will also cover the obligations of executors and administrators under the Federal Priority Act that must be satisfied prior to any distributions to avoid personal liability for those pesky tax issues.

Moderator: 

  • Zhanna A. Ziering, Esq., Moore Tax Law Group, New York, NY

Panelists:   

  • Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ
  • Kristen M. Lynn, Esq., Green & Sklarz LLC, New Haven, CT
  • Jason Freeman, Esq., Freeman Law, Frisco, TX

2:45 – 3:00 pm:

Break

3:00 – 4:00 pm:

Track A: Representing Clients Before a Resource-Challenged IRS

The challenges of dealing with the IRS persist and have now drawn the attention of Congress.  Our panel will review the ongoing issues and what practitioners should be doing with the IRS after filing returns, including the IRS’s suspension of sending certain letters and what that actually means, tax returns that have yet to be processed, resolving disputes over the child tax credit and reconciliation with the Advance CTC, tax liens and payoff letters, and Freedom of Information Act Request responses, among other issues.

Moderator:     

  • Amanda Evans, EA, Green & Sklarz LLC, New Haven, CT

Panelists: 

  • Nina E. Olson, Esq., Center for Taxpayer Rights, Washington, DC
  • Sara V. Spodick, Esq., Quinnipiac University Law School, North Haven, CT
  • Lisa E. Perkins, Esq., Green & Sklarz LLC, West Hartford, CT

Track B: Defending You! Preparer Penalties and Referrals to the OPR

IRS examiners have become very aggressive in pursuing preparer and appraisal penalties when it believes the professional crossed the line. This decision to penalize the professional can be for anything from disagreeing with the valuation you arrived at or even failing to file your own tax returns. These penalties, once paid, will lead to an automatic referral to the IRS Office of Professional Responsibility. The panelists will review the commonly assessed civil penalties, the assessment procedure and applicable statutes of limitations, the right to and procedure for administrative and judicial appeals, and what steps to take with respect to an OPR referral.

Moderator: 

  • Eric L. Green, Esq., Green & Sklarz LLC

Panelists: 

  • Karen L. Hawkins, Esq., Attorney-At-Law, Yachats, OR
  • Guinevere M. Moore, Esq., Moore Tax Law Group, LLC, Chicago, IL
  • Sanford J. Boxermann, Esq., Capes, Sokol, Goodman & Sarachan, PC, St. Louis, MO

4:00 – 5:00 pm:

Track A: Confessions of a Tax Evader: Resolving Criminal Tax Cases with Guilty Pleas

IRS Criminal Investigation and the DOJ Tax Division have an impressive conviction rate. As a result, many taxpayers who are the target of a criminal investigation or who have been indicted are well served to consider resolving their prosecution with a guilty plea. This panel will examine some of the considerations that go into deciding whether a taxpayer should plead guilty and the techniques for negotiating the plea. The panel will also review the impact of tax loss and why the role of the Kovel accountant is so critical.

Moderator: 

  • Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT

Panelists: 

  • Anastasia King, Esq., Asst. United States Attorney, Department of Justice, New Haven, CT
  • Barbara T. Kaplan, Esq., Greenberg Traurig LLP, New York, NY
  • Damon Rowe, Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX

Track B: Gotcha! Challenging Tax Penalties on International Forms

In 2018, the IRS began to automatically assess civil penalties for the failure to file or to accurately file foreign international information returns, including but not limited to Forms 5471, 5472, 8865, 8938, 926, 3520, and 3520A. The mistakes that give rise to these failures are often very minor compared to the amount of the penalties assessed. Under current IRS procedures, the only pre-payment remedy is to rely on the IRS to exercise its discretion to abate the penalties based on reasonable cause. This panel will provide tips for navigating the penalty abatement process to help taxpayers avoid incurring significant penalties for relatively minor foot faults.

Moderator:     

  • Zhanna A. Ziering, Esq., Moore Tax Law Group, New York, NY

Panelists: 

  • Miri Forster, Eisner Advisory Group LLC, New York, NY
  • Laura L. Gavioli, Esq., Alston & Bird, LLP, New York, NY
  • Sanessa S. Griffiths, Esq., Skadden, Arps, Slate, Meagher & Flom, LLP, Washington, DC

Schedule: Saturday, November 19, 2022

7:30 – 9:30 am:

TRN Members Only Private Breakfast

Special TRN Members Only event. Not a member? Learn more

REGISTER NOW FOR ONLY:

FRIDAY: $399 SPECIAL RATE

THURSDAY: $99 with Friday Program

CLICK THE LINK BELOW TO REGISTER NOW!

CLICK HERE TO REGISTER FOR VIRTUAL REGISTRATION

    Presented by

    • Green & Sklarz, LLC
    • One Audubon St, 3rd Floor, New Haven, CT 06511
    • hello@taxrepllc.com
    • https://gs-lawfirm.com
    • https://taxrepllc.com

    IRS Representation Conference Logo White
     

    QUICK LINKS

    • 2021 IRS Representation Conference – Purchase Recordings and Handouts

    © 2023 · New England IRS Representation Conference · Designed by byStorm Studios

    • 2022 IRS Representation Conference
      • Schedule
      • Speakers
      • Sponsors
      • Continuing Education
      • Register for WEBCAST
      • IN-PERSON FULL
    • 2022 Criminal Tax Day
      • Schedule
      • Speakers
      • Sponsors
      • Continuing Education