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9 TH A N N U A L
TA X C O N T R O V E R S Y F O R U M

JUNE 15–16, 2017
CROWNE PLAZA
TIMES SQUARE MANHATTAN
NEW YORK, NY

CONFERENCE CO-CHAIRS:

Bryan C. Skarlatos, Esq., Partner, Kostelanetz & Fink,
New York, NY
David A. Lifson, CPA, Partner, Crowe Horwath,
New York, NY
FINANCE AND LAW PROGRAMS

EXTENDED TO 2 FULL DAYS!

9TH ANNUAL TAX CONTROVERSY FORUM
CO-CHAIRS:
Bryan C. Skarlatos, Esq., Partner, Kostelanetz & Fink, New York, NY
David A. Lifson, CPA, Partner, Crowe Horwath, New York, NY

LEARNING OBJECTIVES
The NYU School of Professional Studies is pleased to present the 9th Annual Tax Controversy
Forum. The Tax Controversy Forum brings together representatives from the government and
expert private practitioners to compare perspectives on a variety of topics involving federal tax
audits, appeals, and litigation. The Forum covers a wide range of controversy work, from procedural
seminars to substantive programs, international issues, ethical problems, current enforcement
initiatives, sensitive audits, and civil and criminal tax penalties.
Enforcement is an essential part of our federal tax system. The Tax Controversy Forum is an
opportunity to stay current on new developments, exchange ideas, and share practice tips, which
can contribute to better functioning of the system. Participants qualify for CPE and CLE credits.
As a premier educational institution, the NYU School of Professional Studies is committed to
providing the highest standard of professional enrichment.

WHO SHOULD ATTEND?
Accountants, attorneys, enrolled agents, in-house practitioners, and tax professionals at all levels
who prepare for or handle audits, appeals, or tax litigation, as well as those involved in planning and
transactional work who could benefit from a better understanding of the implications of their work
for audit defense.

NYU SCHOOL OF PROFESSIONAL STUDIES
Dennis Di Lorenzo, BA, Harvey J. Stedman Dean

DIVISION OF PROGRAMS IN BUSINESS
Martin Ihrig, MBS, PhD, Associate Dean and Clinical Professor

DEPARTMENT OF FINANCE AND LAW PROGRAMS
Kathleen Costello, CMP, Assistant Director

The NYU School of Professional Studies reserves the right to change, with or without notice, any
statement in this brochure concerning, but not limited to, rules, policies, tuition, fees, curriculum,
courses, speakers, and programs.

2 | For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy

CROWNE PLAZA TIMES SQUARE MANHATTAN
NEW YORK, NY
JUNE 15–16, 2017
PLANNING COMMITTEE
PLANNING COMMITTEE CHAIR
Sidney Kess, CPA, JD, LLM, Of Counsel, Kostelanetz & Fink; Senior Consultant, Citrin Cooperman,
New York, NY

PLANNING COMMITTEE MEMBERS
Mark D. Allison, Esq., Member, Caplin & Drysdale, Chartered, New York, NY
David D. Aughtry, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, Atlanta, GA
Howard J. Berman, Esq., Director, Tax Controversy Services, Deloitte Tax, New York, NY
Megan L. Brackney, Esq., Partner, Kostelanetz & Fink, New York, NY
Stephen M. Brecher, CPA, JD, MBA, LLM, CIRA, Senior Advisor, Mazars USA, New York, NY
Sandra R. Brown, Esq., Acting United States Attorney, The United States Attorney’s Office,
Central District of California, Los Angeles, CA
N. Jerold Cohen, Esq., Partner, Eversheds Sutherland (US), Atlanta, GA
Michael J. Desmond, Esq., The Law Offices of Michael J. Desmond, APC, Santa Barbara, CA
Eli J. Dicker, Esq., Executive Director, Tax Executives Institute, Washington, DC
John Gamino, CPA, Esq., Clinical Assistant Professor, Department of Accounting,
University of Texas at Dallas, Dallas, TX
Noelle T. Geiger, Esq., Director and Principal of Tax Controversy Services, Grassi & Co., Jericho, NY
Gersham Goldstein, Esq., Stoel Rives, Portland, OR
Claudia Hill, EA, MBA, President, TaxMam, Cupertino, CA
Kathryn Keneally, Esq., Partner, DLA Piper (US), New York, NY
Robert E. McKenzie, Esq., Partner, Arnstein & Lehr, Chicago, IL
Charles J. (Chad) Muller, III, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry,
San Antonio, TX
Pamela F. Olson, US Deputy Tax Leader and Washington National Tax Services Practice Leader,
PricewaterhouseCoopers, Washington, DC
Kathleen M. Pakenham, Esq., Partner, Cooley, New York, NY
Leon M. Reimer, CPA, Partner, Citrin Cooperman, New York, NY
Martin A. Schainbaum, Esq., Principal, Martin A. Schainbaum, PLC, San Francisco, CA
Robert E. Spierer, CPA, MBA, Partner, Perelson Weiner, New York, NY

For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy | 3

9TH ANNUAL TAX CONTROVERSY FORUM SPONSORS
The NYU School of Professional Studies thanks the following organizations for their contribution
to the enhancement and the continued success of the Tax Controversy Forum:

PROGRAM SPONSOR:

PLATINUM SPONSORS:

GOLD SPONSORS:

SILVER SPONSORS:

JUNE 15–16, 2017
CROWNE PLAZA TIMES SQUARE MANHATTAN
NEW YORK, NY

THURSDAY, JUNE 15, 2017
8:00 a.m.
REGISTRATION AND DISTRIBUTION OF MATERIALS
CONTINENTAL BREAKFAST
8:30 a.m.
OPENING REMARKS
8:40 a.m.
TAX COMPLIANCE AND ENFORCEMENT UPDATE PART I

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the
past several years, the IRS and DOJ have been challenged to come up with new and more efficient
ways to ensure that all taxpayers pay the correct amount of tax. This panel provides an update on
new developments and priorities across the IRS and DOJ.

IRS LARGE BUSINESS AND INTERNATIONAL DIVISION UPDATE

Thomas J. Kane, Esq., Division Counsel, Office of Chief Counsel, Large Business & International
Division, Internal Revenue Service, Washington, DC
Interviewer: Thomas A. Cullinan, Esq., Partner, Eversheds Sutherland (US), Atlanta, GA

IRS SMALL BUSINESS/SELF-EMPLOYED DIVISION UPDATE

Mary Beth Murphy, Commissioner, Small Business/Self-Employed Division, Internal Revenue Service,
Washington, DC
Interviewer: Sheldon M. Kay, Esq., CPA, Principal-in-Charge of Washington National Tax,
Crowe Horwath, Washington, DC

IRS COLLECTION OPERATIONS UPDATE

Phyllis Brown, SB/SE Director, Headquarters Collection, Internal Revenue Service, Washington, DC
Interviewer: Frank Agostino, Esq., President, Agostino & Associates, PC, Hackensack, NJ

IRS CRIMINAL INVESTIGATION DIVISION UPDATE

Richard Weber, Esq., Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC
Interviewer: Josh O. Ungerman, Esq., CPA, Partner, Meadows, Collier, Reed, Cousins,
Crouch & Ungerman, Dallas, TX

10:00 a.m.
LB&I COMPLIANCE CAMPAIGNS: WHAT ARE THEY, WHY DO WE HAVE THEM,
AND HOW WILL THEY AFFECT TAXPAYERS?

In January 2017, the IRS Large Business and International Division announced 13 campaigns covering
a range of issues and industries on which it will focus its compliance and enforcement resources.
This new issue-based approach is intended to help conserve IRS resources and create a more
efficient examination process. The Compliance Campaigns are a major change in the compliance
landscape for LB&I taxpayers and raise many questions about how the campaigns will operate, how
taxpayers will be affected, what can be expected from the new process, and what will change in the
way the IRS conducts examinations. This panel explores these questions and more as it addresses the
practical implications of this shift in approach.
Moderator: Sharon Katz-Pearlman, Esq., National Principal-in-Charge, Tax Controversy Services,
KPMG, New York, NY; Global Head, Tax Dispute Resolution and Controversy, KPMG International
Kevin Brown, Esq., Principal, Leader, Tax Controversy and Regulatory Services,
PricewaterhouseCoopers, Washington, DC
Armando Gomez, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, Washington, DC
Thomas J. Kane, Esq., Division Counsel, Office of Chief Counsel, Large Business & International
Division, Internal Revenue Service, Washington, DC

11:00 a.m.
REFRESHMENT BREAK

For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy | 5

9 TH ANNUAL
TAX CONTROVERSY FORUM
11:15 a.m.
KEYNOTE ADDRESS

The IRS Taxpayer Advocate addresses current issues facing the IRS with respect to tax compliance,
enforcement, and administration.
Nina E. Olson, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC

12:15 – 1:15 p.m.
LUNCHEON
BUFFET LUNCH SERVED
1:15 – 2:15 p.m.
BREAKOUT SESSIONS

TRACK I
INTERNATIONAL EXCHANGE OF INFORMATION AND EVIDENCE GATHERING

In an increasingly globalized economy, taxpayers—from multinational corporations to globe-trotting
individuals—can have financial dealings and information relevant to tax enforcement in many different
countries. International agreements, including treaties, tax information exchange agreements,
automatic exchange agreements, and local laws, dramatically affect whether and how information
can be obtained and shared with other countries’ tax authorities. This panel examines the various
methods that are used and issues that arise when one country’s tax authorities seek information and
evidence within the jurisdiction of another country.
Moderator: Caroline D. Ciraolo, Esq., Former Acting Assistant Attorney General, Tax Division,
US Department of Justice, Washington, DC
Nancy Chassman, Esq., Partner, Roberts & Holland, New York, NY
Lindsay L. Clayton, Esq., Trial Attorney, Tax Division, US Department of Justice, Washington, DC
Don Fort, Deputy Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC
Jeffrey A. Neiman, Esq., Partner, Marcus Neiman & Rashbaum, Fort Lauderdale, FL

TRACK II
DOING MORE WITH LESS: THE USE OF PRIVATE AGENCIES
TO COLLECT FEDERAL TAX DEBTS

For at least a decade, private collection agencies have been used to collect federal, state, and
municipal debt. Several states, including the State of New Jersey, have employed private collection
agencies to assist in the collection of outstanding state taxes. In December 2015, Congress passed a
law requiring the IRS to use private debt collection agencies to help collect unpaid federal taxes. This
panel discusses how the IRS plans to incorporate private debt collection agencies into the federal tax
collection regime.
Moderator: Frank Agostino, Esq., President, Agostino & Associates, PC, Hackensack, NJ
Phyllis Brown, SB/SE Director, Headquarters Collection, Internal Revenue Service, Washington, DC
E. Martin Davidoff, CPA, Esq., Managing Member, E. Martin Davidoff & Associates CPAs, Dayton, NJ
Thomas MacDonald, Chief of Operations, Treasury, New Jersey Division of Taxation, Trenton, NJ

2:15 p.m.
REFRESHMENT BREAK

6 | For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy

JUNE 15–16, 2017
CROWNE PLAZA TIMES SQUARE MANHATTAN
NEW YORK, NY

2:40 – 3:40 p.m.
BREAKOUT SESSIONS

TRACK I
INTERNATIONAL ENFORCEMENT: WHAT’S HAPPENING NEXT IN
THE BATTLE AGAINST UNREPORTED FOREIGN ASSETS

For years now, the IRS and DOJ have focused resources on unreported foreign assets. This trend
shows no sign of abating. To the contrary, as the government learns more about foreign financial
institutions and foreign advisors, US enforcement is moving to different jurisdictions, utilizing new
techniques, benefitting from greater international cooperation, and exploring more complex and
sophisticated cases. Even eight years after the UBS Deferred Prosecution Agreement, US taxpayers
and their advisors can expect increasing and aggressive activity in this area. This panel discusses what
is happening now and what we can expect over the next year in this fertile area of tax enforcement.
Moderator: Scott D. Michel, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
Thomas E. Bishop, Senior Manager, National Forensic, Litigation and Valuation Services,
Baker Tilly Virchow Krause, New York, NY
Nanette L. Davis, Esq., Senior Litigation Counsel, Tax Division, US Department of Justice,
Washington, DC
Carolyn A. Schenck, Esq., Senior Counsel, Office of Chief Counsel, Internal Revenue Service, St. Paul, MN

TRACK II
LOSING YOUR DRIVER’S LICENSE, PASSPORT, OR WORSE:
COLLATERAL SANCTIONS FOR TAX NON-COMPLIANCE

It is not unusual for the IRS or state tax authorities to assess monetary penalties for failure to
report or pay taxes. More recently, new laws have been developed to impose additional sanctions,
such as denial of hunting permits, suspension of driver’s licenses, revocation of passports, and even
deportation, to penalize tax non-compliance. This panel reviews those new laws and explores how
they can affect your clients.
Moderator: Joshua D. Blank, Esq., Professor of Tax Law, Faculty Director of the Graduate Tax
Program, NYU School of Law, New York, NY
Argi O’Leary, Esq., Deputy Commissioner, Civil Enforcement Division, New York State Department of
Taxation and Finance, Albany, NY
Nina E. Olson, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC
Yvonne R. Cort, Esq., Partner, Capell Barnett Matalon & Schoenfeld, Jericho, NY

3:40 p.m.
REFRESHMENT BREAK
4:00 – 5:00 p.m.
BREAKOUT SESSIONS

TRACK I
CAPTIVE INSURANCE: THE GOOD, THE BAD, AND THE UGLY

Over the past several years, the IRS has seen an uptick in the number of small and medium
businesses that take advantage of special rules allowing small insurance companies to avoid tax on
a limited amount of premium income. While many of these arrangements are completely legitimate
insurance vehicles, some of the arrangements are abusive schemes that exist merely to provide tax
benefits. The IRS recently has designated such abusive arrangements as Transactions of Interest
and the subject of a specific LB&I Compliance Campaign. This panel discusses the line between
legitimate insurance and an abusive tax shelter and the ways the IRS examines and challenges
these arrangements.
Moderator: Rachel L. Partain, Esq., Member, Caplin & Drysdale, Chartered, New York, NY
Miriam L. Fisher, Esq., Global Chair of Tax Controversy, Latham & Watkins, Washington, DC
M. Kristan Rizzolo, Esq., Partner, Eversheds Sutherland (US), Washington, DC
Steven R. Toscher, Esq., Principal, Hochman, Salkin, Rettig, Toscher & Perez, PC, Beverly Hills, CA

For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy | 7

9 TH ANNUAL
TAX CONTROVERSY FORUM
TRACK II
WHAT’S HAPPENING NOW WITH NEW YORK STATE CIVIL TAX ENFORCEMENT

Compliance, enforcement, and collection of taxes are top priorities for the New York State
Department of Taxation and Finance. This panel of distinguished public and private practitioners
discusses New York State’s current programs and priorities.
Moderator: Karen J. Tenenbaum, Esq., CPA, Partner, Tenenbaum Law, PC, Melville, NY
Argi O’Leary, Esq., Deputy Commissioner, Civil Enforcement Division, New York State Department of
Taxation and Finance, Albany, NY
Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY
Jack Trachtenberg, Esq., Principal, Deloitte Tax, New York, NY

5:00 p.m.
RECESS

FRIDAY, JUNE 16, 2017
8:00 a.m.
REGISTRATION AND DISTRIBUTION OF MATERIALS
CONTINENTAL BREAKFAST
8:30 a.m.
OPENING REMARKS
8:40 a.m.
TAX COMPLIANCE AND ENFORCEMENT UPDATE PART II

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the
past several years, the IRS and DOJ have been challenged to come up with new and more efficient
ways to ensure that all taxpayers pay the correct amount of tax. This panel provides an update on
new developments and priorities across the IRS and DOJ.

DEPARTMENT OF JUSTICE UPDATE

David A. Hubbert, Esq., Acting Assistant Attorney General, Tax Division, US Department of Justice,
Washington, DC
Interviewer: Caroline D. Ciraolo, Esq., Former Acting Assistant Attorney General, Tax Division,
US Department of Justice, Washington, DC

IRS WHISTLEBLOWER OFFICE UPDATE

Lee D. Martin, PMP, Director, Whistleblower Office, Internal Revenue Service, Washington, DC
Interviewer: Dean Zerbe, Esq., Partner, Zerbe, Miller and Fingeret, Houston, TX

US TAX COURT UPDATE

The Honorable L. Paige Marvel, Chief Judge, United States Tax Court, Washington, DC
Interviewer: Charles P. Rettig, Esq., Principal, Hochman, Salkin, Rettig, Toscher & Perez, PC,
Beverly Hills, CA

8 | For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy

JUNE 15–16, 2017
CROWNE PLAZA TIMES SQUARE MANHATTAN
NEW YORK, NY

9:45 a.m.
THE WORLD IS CHANGING ON JANUARY 1, 2018: THE NEW PARTNERSHIP AUDIT
RULES AND WHAT THEY MEAN FOR YOU

The new partnership audit rules enacted in 2015 are effective for tax years beginning after December
31, 2017, and the old TEFRA partnership audits rules will no longer apply. Nearly all partnerships, from
small family limited partnerships to publicly traded partnerships with thousands of partners, will have
to interact with the IRS in new and different ways. This panel outlines some of the most significant
changes and issues for which taxpayers must be prepared.
Moderator: Fred F. Murray, Esq., CPA, Professor of Law, University of Florida Levin College of Law,
Gainesville, FL
Jerald David August, Esq., Partner, Kostelanetz & Fink, New York, NY
Gregory T. Armstrong, Esq., Senior Technician Reviewer, Office of the Associate Chief Counsel
(Procedure and Administration), Internal Revenue Service, Washington, DC
Diana L. Wollman, Esq., Partner, Cleary Gottlieb Steen & Hamilton, New York, NY

10:45 a.m.
REFRESHMENT BREAK
11:00 a.m.
READING BODY LANGUAGE TO EVALUATE TRUTHFULNESS

Whether you are an attorney, accountant, agent or investigator, you often are faced with the
challenge of evaluating the truthfulness of others who may have been involved in deceptive or
dishonest behavior. There is no reason to be left in the dark, wondering why you didn’t see the clues
to deception that seem so obvious in hindsight. Detecting deception is a learned skill, and the truth
is often right before your eyes when you know what to look for. Susan Constantine has spoken to and
trained representatives of the FBI, DEA, Homeland Security, state prosecutor and public defender
offices, and numerous private corporations and organizations.
Susan Constantine, MPsy, Body Language Expert, Orlando, FL

12 Noon
LUNCH RECESS
1:15 – 2:15 p.m.
BREAKOUT SESSIONS

TRACK I
WHAT WORKS AND WHAT DOESN’T IN APPEALS

As the old saying goes “the deals are in Appeals.” However, recent structural and procedural changes
at the IRS Office of Appeals make it more important than ever for taxpayers and their representatives
to prepare in advance for Appeals conferences. This panel discusses the factors that help resolve
cases and practical strategies for getting a “deal.”
Moderator: Sheldon M. Kay, Esq., CPA, Principal-in-Charge of Washington National Tax,
Crowe Horwath, Washington, DC
Daniel A. Dumezich, National Leader of Federal Tax Controversy Services, Deloitte Tax, Chicago, IL
Donna C. Hansberry, Esq., Chief, Appeals, Internal Revenue Service, Washington, DC
Brian W. Kittle, Esq., Partner, Mayer Brown, New York, NY

For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy | 9

9 TH ANNUAL
TAX CONTROVERSY FORUM
TRACK II
THE EXPANDING SCOPE OF 7212: WHEN DOES FRUSTRATING
THE IRS BECOME CRIMINAL?

Taxpayers frequently make the IRS’s job harder by failing to maintain accurate business records,
reporting or structuring transactions in a way that reduces the red flags for audit, or resisting
requests for information or interviews in an audit. But when do taxpayers and their advisors cross the
line and commit a felony by “corruptly” obstructing or impeding the administration of the tax laws?
Recent cases demonstrate that the line is uncomfortably blurry, and this panel of expert private and
public practitioners explores the boundaries of the omnibus clause of Section 7212.
Moderator: Jenny L. Johnson, Esq., Partner, Johnson Moore, Chicago, IL
Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA
Jeremy H. Temkin, Esq., Principal, Morvillo Abramowitz Grand Iason & Anello PC, New York, NY
Todd A. Ellinwood, Esq., Assistant Chief, Southern Criminal Enforcement Section, Tax Division,
US Department of Justice, Washington, DC

2:15 p.m.
REFRESHMENT BREAK
2:40 – 3:40 p.m.
BREAKOUT SESSIONS

TRACK I
DOING YOUR HOMEWORK: HOW TO PREPARE A CASE FOR TAX COURT

It has been said that the key to winning at trial is preparation. Focus on discovery and pre-trial
procedure can make the difference between winning and losing. From drafting the petition, to the
Branerton letter, document requests, depositions, requests to admit, stipulations of fact, and the
pre-trial order, this panel of experienced practitioners and a Tax Court Judge discusses how best to
position your case before the first day of trial.
Moderator: Todd Welty, Esq., Partner and Co-Chair Tax Controversy Practice,
McDermott Will & Emery, Dallas, TX
Lawrence M. Hill, Esq., Partner, Winston & Strawn, New York, NY
The Honorable L. Paige Marvel, Chief Judge, United States Tax Court, Washington, DC
Peter N. Scharff, Esq., Senior Attorney, Office of Chief Counsel, Small Business/Self-Employed
Division, Internal Revenue Service, New York, NY

TRACK II
STEPPING LIGHTLY: PRACTICAL ADVICE FOR HANDLING ETHICAL
AND SENSITIVE ISSUES IN A CIVIL AUDIT

Unaccounted for transactions, unusual corporate deductions, and overly aggressive interpretations
of the Internal Revenue Code are hallmarks of a sensitive-issue audit. These are the kinds of issues
that keep practitioners awake at night. This panel addresses strategies for successfully navigating
the ethical and legal issues that arise in a sensitive-issue audit while continuing to zealously
represent your client.
Moderator: Richard J. Sapinski, Esq., Partner, Sills Cummis & Gross PC, Newark, NJ
James D. Robnett, Special Agent-in-Charge, Internal Revenue Service, Criminal Investigation,
Chicago Field Office, Chicago, IL
Michael Sardar, Esq., Associate, Kostelanetz & Fink, New York, NY
Philip J. Wilson, CPA, Partner-in-Charge, California Region, Marcum, Irvine, CA

10 | For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy

JUNE 15–16, 2017
CROWNE PLAZA TIMES SQUARE MANHATTAN
NEW YORK, NY

3:40 p.m.
REFRESHMENT BREAK
4:00 – 5:00 p.m.
BREAKOUT SESSIONS

TRACK I
BUT IT’S NOT MY FAULT! DEVELOPING A ROBUST REASONABLE
CAUSE DEFENSE TO PENALTIES

Taxpayers can establish reasonable cause for a tax understatement and avoid penalties by proving
that they attempted in good faith to determine their proper tax liability. One of the primary ways
taxpayers attempt to determine their proper tax liability is by obtaining professional advice.
However, simply paying for an opinion does not go far enough to avoid penalties. This panel
discusses the increasingly technical rules for when reliance on professional advice is sufficient to
establish reasonable cause.
Moderator: Larry A. Campagna, Esq., Shareholder, Chamberlain, Hrdlicka, White,
Williams & Aughtry, Houston, TX
Matthew J. Avon, Esq., Special Trial Attorney, Office of Chief Counsel, Internal Revenue Service,
New York, NY
Brian R. Harris, Esq., Partner, Akerman, Tampa, FL
Frank J. Jackson, Esq., Partner, DLA Piper (US), New York, NY
Lawrence W. Sherlock, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry,
Houston, TX

TRACK II
WAKING UP THE DEAD: REOPENING THAT ASSESSMENT
YOUR CLIENT THOUGHT WAS FINAL

From overlooked notices to procedural missteps, taxpayers sometimes find themselves with a tax
assessment that they should not owe. While paying and suing for a refund is theoretically possible,
full payment is not always a practical option. This panel reviews techniques for practitioners to
reopen and correct these assessments through procedures such as a Collection Due Process Hearing,
a request for audit reconsideration, or the filing of a doubt as to liability Offer in Compromise.
Moderator: Eric L. Green, Esq., Partner, Green & Sklarz, New Haven, CT
Phyllis Brown, SB/SE Director, Headquarters Collection, Internal Revenue Service, Washington, DC
Eduardo S. Chung, Esq., Senior Manager, Mazars USA, New York, NY
Walter Pagano, CPA, CFE, CFF, Partner, Tax Controversy Practice Leader, Forensic Accountant and
Litigation Consultant, EisnerAmper, New York, NY
David A. Shuster, Esq., Director, International & Tax Controversy Services, Friedman, New York, NY

5:00 p.m.
CONFERENCE CONCLUDES

For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy | 11

9 TH ANNUAL
TAX CONTROVERSY FORUM
GENERAL INFORMATION
CONFERENCE FEE
The conference fee of $995 includes tuition, continental breakfast, refreshment breaks, lunch on day
one, and one set of course materials on a USB flash drive. Full and partial waivers of the Conference
fee based upon financial need are available as well. To request a waiver application, please
call 212-992-3320 or email your request to sps.tax@nyu.edu.

SINGLE-DAY REGISTRATION FEE
The single-day conference fee of $575 includes tuition for one day of sessions, continental breakfast,
refreshment breaks, lunch on day one (if applicable for the selected day), and one set of course
materials on a USB flash drive for the day of attendance.

FULL-TIME GOVERNMENT OFFICIAL REGISTRATION FEES
If you are a full-time government official, the fee is $195 for one day or $295 for both days. You must
provide proof of full-time government employment with registration. To register online for the fulltime government official discount, please call 212-992-3320 or email sps.tax@nyu.edu for a special
discount code.
You may register online, by mail, or onsite at the conference. We can only accept credit card
payments through the online payment portal. We do not accept faxed registrations or wire
transfers as a form of payment. To register by mail, complete the registration form and return it
with a check or money order. All registrations sent by mail must be received by 12 noon (EDT) on
Tuesday, June 13, 2017.
To register onsite, you may pay by check, money order, or credit card. To pay by credit card, all walkins will be required to self-register at available kiosks. For faster service, conference attendees should
plan to register in advance online at sps.nyu.edu/taxcontroversy.

PRESS BADGES
If your publication plans to cover the NYU School of Professional Studies 9th Annual Tax Controversy
Forum, please email coverage and press credentials to sps.press@nyu.edu.

ELECTRONIC REGISTRATION CONFIRMATION
An automated email confirmation will be sent to the email address provided to the NYU School
of Professional Studies at the time of registration. Please use an individual email address for each
registrant. If a confirmation is not received within two days of online registration submission (allow
one to two weeks for registrations sent by mail), email sps.tax@nyu.edu to request a duplicate copy.

CONFERENCE LOCATION AND HOTEL ACCOMMODATIONS
The Conference will be held at the Crowne Plaza Times Square Manhattan, 1605 Broadway and
49th Street. Accommodations are available at the hotel, which is easily accessible to Times Square,
Broadway theatres, Radio City Music Hall, Carnegie Hall, Rockefeller Center, Central Park, and Fifth
Avenue shopping. To provide a quality conference at the best possible cost, the NYU School of
Professional Studies has negotiated special room rates and has committed to a block of rooms at
the Crowne Plaza Times Square. We ask you to support the NYU School of Professional Studies by
reserving your sleeping accommodations within the room block. Your support allows us to keep our
registration fees reasonable. Single- or double-occupancy rooms are available at the NYU School of
Professional Studies group rate of $329 by calling 888-233-9527 and referring to the NYU School of
Professional Studies Tax Forum. These rooms will be held as a block, unless exhausted, until May 15,
at which time they will be released to the general public. Book your reservation in advance, as hotel
rooms can sell out prior to the cut-off date.

CANCELLATION AND SUBSTITUTION POLICY
A written request for cancellation must be emailed to sps.tax@nyu.edu to the attention of:
Conference Administration. Requests received by May 31 will receive a 100% tuition refund, less a
$150 cancellation fee. Due to financial obligations incurred by the NYU School of Professional Studies,
there are no refunds available after May 31. We are not able to arrange cancellation exceptions or
to accept onsite cancellations. If you cannot attend but would like to send someone in your place,
please email sps.tax@nyu.edu no later than June 13.

12 | For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy

JUNE 15–16, 2017
CROWNE PLAZA TIMES SQUARE MANHATTAN
NEW YORK, NY

CONFERENCE MATERIALS
Course materials are provided for each day of the Forum for which you are registered. NEW! Registrants
will receive a USB flash drive, which is included in the conference fee, at the time of check-in that
contains the materials for the day(s) of attendance. In addition, registrants will receive an email from
NYU approximately 2–3 days before the Forum, which contains a link and special password in order
to access and to download and/or print the course materials for the day(s) of attendance. Free Wi-Fi
will be available for attendees at the Conference. Bound hard copies of the course materials will be
available only upon advanced request for an additional fee of $200. If you wish to have a printed
set of materials available at the NYU Registration Desk for the day(s) of your attendance, please
indicate this when registering and submit the additional fee of $200. Printers will not be available at
the conference. Please note that materials not provided to NYU in advance may be available in hard
copy onsite and/or may be emailed to registrants after the Forum upon request. However, last-minute
materials will not be on the USB flash drive. If you are unable to attend the Forum but would like to
receive a copy of the course materials on a USB flash drive, please send your request to NYU 9th
Annual Tax Controversy Forum Course Materials Order, 11 West 42nd Street, Suite 400, New York,
NY 10036; call 212-992-3320; or email sps.tax@nyu.edu to reserve your copy. See the Conference
Registration Form for further details on how to order course materials.

CONFERENCE CHECK-IN AND MATERIALS PICK-UP
The NYU School of Professional Studies Tax Controversy Forum Registration Desk will open, and
materials will be available, at 8 a.m. on Thursday and Friday. Proper photo identification is required
for badge retrieval. One set of conference materials per paid registrant is provided at the time of
badging. Badges must be displayed in all public spaces throughout the Conference.

SPECIAL NEEDS
Any participant who has special needs (physical or dietary) is encouraged to email sps.tax@nyu.edu
or to call the Department of Finance and Law Programs at 212-992-3320 at least two weeks prior to
the Conference start date to indicate his/her particular requirement.

CONTINUING EDUCATION CREDIT
The NYU School of Professional Studies is a recognized leader in professional continuing education.
The NYUSPS Department of Finance and Law Programs has been certified by the New York State
Continuing Legal Education Board as an Accredited Provider of continuing legal education in the
State of New York. This conference meets the educational requirements of many organizations
and agencies with mandatory CLE/CPE filing requirements. We urge you to contact our office at
212-992-3320 or at sps.tax@nyu.edu at least 30 days prior to the Conference start date to ensure
the availability of credit for a specific MCLE state, as we cannot guarantee that credit will be applied
for in all cases.

ESTIMATED CONTINUING EDUCATION CREDITS
11.0 based upon a 60-minute hour, including 1.0 ethics credit
13.5 based upon a 50-minute hour, including 1.0 ethics credit
Except where indicated, CLE credits are non-transitional in the categories of professional practice/
practice management. CLE boards define a credit hour as either 60 minutes or 50 minutes.
Recommended CPE credits are in the following NYS subject area: Taxation. NASBA Fields of
Study: Taxes; Regulatory Ethics. In accordance with the Standards of the National Registry of
CPE Sponsors, CPE credits are based upon a 50-minute hour. Please note that not all state boards
accept half credits.

NASBA
The NYU School of Professional Studies Department of Finance and Law Programs 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: nasbaregistry.org.
Program Level: Overview. Delivery Method: Group live. Fields of Study: Taxes; Regulatory Ethics.
Prerequisites: No prerequisite. Advanced Preparation: No advanced preparation required.
New York and Texas require sponsors to individually register with their states as continuing
professional education sponsors; the NYU School of Professional Studies is a registered sponsor
in the State of New York (Sponsor ID# 000493) and the State of Texas (Sponsor ID# 000439).
(continued on next page)

For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy | 13

9 TH ANNUAL
TAX CONTROVERSY FORUM
GENERAL INFORMATION (continued)
IRS CONTINUING PROFESSIONAL EDUCATION CREDITS
The NYU School of Professional Studies is a qualified sponsor
(Sponsor #673) of continuing professional education required
for individuals enrolled to practice before the Internal Revenue
Service (enrolled agents).
A certificate of attendance is given to each registrant and validated upon completion of the
program. For questions concerning credit hours or approvals, please call 212-992-3320 or
email sps.tax@nyu.edu.

SPONSORSHIP AND EXHIBIT OPPORTUNITIES
For information on becoming a Forum Sponsor or exhibiting at the Conference, please contact
Kathleen Costello at 212-992-3320 or kathleen.costello@nyu.edu.

RECORDING DEVICES
The use of tape or digital recorders in meeting rooms is prohibited. Please switch off mobile phones,
email devices, etc., upon entering the meeting room.

REGISTRATION INSTRUCTIONS
ONLINE REGISTRATION
• Visit sps.nyu.edu/taxcontroversy
• Highly recommended for fastest response
• A
 utomated email confirmation will be sent to the email address provided to the
NYU School of Professional Studies at the time of registration
• Please use an individual email address for each registrant
• Major credit cards accepted: American Express®, Discover®, MasterCard®, or VISA®

OTHER REGISTRATION OPTIONS
Mail: To register by mail, complete the registration form, and return it with a check or money order
made payable to New York University. Mail to the address below. Payment must accompany the
registration form. An email confirmation of registration will be sent to the email address provided
to the NYU School of Professional Studies. Fill out a separate form for each registration. Send to:
NYU School of Professional Studies Budget Office, New York University, 7 East 12th Street, 12th Floor,
New York, NY 10003, Attention: 9th Annual Tax Controversy Forum.
Onsite: To register onsite, you may pay with check, money order, or credit card. To pay by credit
card, all walk-ins will be required to self-register at available kiosks. For faster service, conference
attendees should plan to register in advance online at sps.nyu.edu/taxcontroversy.
All registrations sent by mail must be received by 12 noon (EDT) on Tuesday, June 13, 2017. To register
onsite, visit the NYU School of Professional Studies registration desk at the Crowne Plaza Times
Square Manhattan beginning at 8 a.m. on Thursday, June 15, 2017.
Note: Each person attending the 9th Annual Tax Controversy Forum must register individually by
using a separate form, or in a separate online registration session. Sharing registrations is NOT
permitted. Only registered attendees are eligible to receive continuing education credits.
To register online for the Full-Time Government Official Discount, please call 212-992-3320 or email
sps.tax@nyu.edu for a special discount code. To qualify, proof of employment will be required.
We can only accept credit card payments through the online payment portal. We do not accept
faxed registrations or wire transfers as a form of payment.
For further information regarding administrative policies, such as complaints and refunds,
or if you need help registering, please call our conference administrators at 212-992-3320 or
email sps.tax@nyu.edu.

14 | For more information, call 212-992-3320. Register online at sps.nyu.edu/taxcontroversy

REGISTRATION FORM
Online:

sps.nyu.edu/taxcontroversy

Mail To: NYU School of Professional Studies Budget Office
New York University
7 East 12th Street, 12th Floor
New York, NY 10003
Attention: 9th Annual Tax Controversy Forum

CHECK ONE FOR REGISTRATION AND PAYMENT:
Individual Conference Registration:

Full-Time Government Official Registration:
To qualify, please enclose identification.

 th Annual Tax Controversy Forum,
9
Thursday–Friday, June 15–16, 2017 for $995

 ull-Time Government Official Registration
F
for $295

 ay One, Thursday, June 15, 2017
D
ONLY for $575

 ay One, Thursday, June 15, 2017 ONLY
D
for $195

 ay Two, Friday, June 16, 2017
D
ONLY for $575

 ay Two, Friday, June 16, 2017 ONLY
D
for $195

PRINTED COURSE MATERIALS—Extra Option for an Additional Fee
We are going green; to help defray costs, printed materials are available for an additional $200.
Check here if you want a bound copy of the materials for the day(s) of your attendance and
include the $200 fee.
Printed Materials for $200
Included in the conference fee, registrants will be provided access to download and/or print
the course materials prior to the Forum and also will receive a USB flash drive at the time of
check-in containing the materials for the day(s) of attendance.
I am a/n

CPA

I require

CLE Credit

Attorney

EA

Other

CPE Credit

FOR CLE ONLY: For which state(s) is CLE credit being requested? State:
Print or type clearly. Please DO NOT abbreviate. This information will appear on the attendee list and on your badge.
(Email addresses will not be publicized.)

Name:
Firm:
Address:
City:

State:

Zip Code:

Business Phone:
Email*:
(*Email is required—registration confirmations are sent via email.)

CAN’T ATTEND
If you are unable to attend the Forum but would like to receive a copy of the course materials
on a USB flash drive, please send your request to NYU School of Professional Studies, Tax
Controversy Forum Course Materials Orders, 11 West 42nd Street, Suite 428, New York, NY
10036; call 212-992-3320; or email sps.tax@nyu.edu to reserve your copy by May 31, 2017. We
cannot guarantee fulfillment after May 31. The price for each set of materials is $200. There is
no additional charge for shipping and handling in the continental US; please add an additional
$20 when shipping orders outside of the continental US. Please make check or money order
payable to New York University, or email sps.tax@nyu.edu to learn how to pay by credit card.
Materials are mailed at the conclusion of the Tax Controversy Forum.
Please send me the 9th Annual Tax Controversy Forum Course Materials
Name:
Firm:
Address:
City:
Business Phone:
Email:

State:

Zip Code:

For more information, call 212-992-3320
visit sps.nyu.edu/taxcontroversy
email sps.tax@nyu.edu

• PRACTICAL ADVICE FOR HANDLING ETHICAL
AND SENSITIVE ISSUES IN A CIVIL AUDIT

• THE EXPANDING SCOPE OF 7212

• WHAT WORKS AND WHAT DOESN’T IN APPEALS

• LB&I COMPLIANCE CAMPAIGNS

DON’T MISS PROGRAMS ON:

EXTENDED TO TWO FULL DAYS!

P1617-0111 05/17

Phyllis Brown, SB/SE Director, Headquarters Collection,
Internal Revenue Service
David A. Hubbert, Esq., Acting Assistant Attorney General,
Tax Division, US Department of Justice
Thomas J. Kane, Esq., Division Counsel, Office of Chief Counsel,
Large Business & International Division, Internal Revenue Service
Lee D. Martin, PMP, Director, Whistleblower Office,
Internal Revenue Service
The Honorable L. Paige Marvel, Chief Judge, United States
Tax Court
Mary Beth Murphy, Commissioner, Small Business/Self-Employed
Division, Internal Revenue Service
Nina E. Olson, Esq., National Taxpayer Advocate,
Internal Revenue Service
Richard Weber, Esq., Chief, Criminal Investigation Division,
Internal Revenue Service

UPDATES FROM:

NEW YORK, NY

CROWNE PLAZA
TIMES SQUARE MANHATTAN

JUNE 15–16, 2017

9 TH A N N UA L TAX
CO N T R OV E R SY F O R U M

Finance and Law Programs
9th Annual Tax Controversy Forum
11 West 42nd Street, Suite 400A
New York, NY 10036

ATTENTION MAIL ROOM: If the individual
whose name is on the label is no longer employed,
please forward this material to his/her successor.



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