17th Annual Tax Controversy Forum 2025 – Track III (Presented by NYU School of Professional Studies)

Caroline D. Ciraolo, Esq., Partner | Kostelanetz

Caroline Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Michael J. Desmond, Esq., Member and Co-Chair of Tax Controversy Group | Miller & Chevalier, Chartered

Michael Desmond’s practice covers a broad range of federal tax matters with a focus on administrative tax policy, tax controversy, and litigation. He represents clients in approaches to the Internal Revenue Service (IRS) and the U.S. Department of the Treasury (Treasury) on administrative rulemaking matters and matters relating to tax administration and enforcement, seeking clarity on the application of federal tax laws. He also represents clients before the examination divisions of the IRS, the IRS Independent Office of Appeals, and in the U.S. Tax Court, federal district courts, the Court of Federal Claims, and federal courts of appeal. Mike is described by clients in Chambers USA as “very smart, strategic, and knowledgeable of tax law,” “responsive and insightful,” noting that “[h]is knowledge of complex matters is incredibly valuable.”

Sharon Katz-Pearlman, Esq., Shareholder | Greenberg Traurig

Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, and other taxpayers, before the IRS. She represents clients from the pre-exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. In addition, Sharon has represented clients using the full range of IRS Alternative Dispute Resolution techniques which are available to taxpayers, and advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs.

Loren C. Ponds, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

Loren Ponds leverages her extensive tax policy experience to provide strategic counsel to clients across industries on a variety of legislative and regulatory issues. She also frequently advises on technical matters related to international tax, including controversy and transfer pricing.

Scott Levine, Esq., Former Deputy Assistant Secretary | International Tax Affairs

Scott Levine the Former Deputy Assistant Secretary (International Tax Affairs) and Tax partner in Baker McKenzie’s Tax Practice Group, based in the Firm’s DC office.
Prior to joining the Firm, Scott most recently served as the Deputy Assistant Secretary (International Tax Affairs) in the US Department of the Treasury, where he led the Office of Tax Policy’s work on international affairs, including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2.

Joshua Odintz, Esq., Partner | Holland & Knight

Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters. He is a co-leader of the Public Policy & Regulation Group’s Tax Policy Team.

Terry Lemons, Former Communications & Liaison Chief | Internal Revenue Service

Terry Lemons spent more than 26 years at the IRS in a variety of roles overseeing the agency’s communications efforts. Before retiring from the government in February, Lemons worked 11 years as the IRS Chief of Communications and Liaison, where he served as a principal advisor to the Commissioner and IRS leadership. In this role, he navigated some of the toughest communications scenarios in government while leading a 325-person team and overseeing the agency’s work with the tax professional community, Congress, the news media as well as internal communications to 100,000 employees.

Emily P. Hughes, PC, Esq. Partner | Kirkland & Ellis

Emily P. Hughes is a litigation partner in the Washington, D.C., office of Kirkland & Ellis LLP. Her practice focuses on counseling and defense of companies, partnerships, individuals, and non-profits in civil and criminal matters, particularly where tax or other complex financial matters are involved. Emily is a problem solver who is uniquely attuned to the needs and issues confronting closely-held enterprises, including private equity sponsors and their founders and shareholders in private companies.

Elizabeth Askey, Esq., Chief | IRS Independent Office of Appeals

Liz Askey is Chief of the Independent Office of Appeals at the Internal Revenue Service (IRS). In this role, she provides leadership and direction over nationwide programs designed to fairly and impartially resolve tax controversies without litigation on the behalf of the federal government and taxpayers.

Jennifer Breen, Esq., Partner | Morgan Lewis & Bockius

Jennifer Breen represents domestic and multinational businesses, large partnerships, high-net-worth individuals, and family offices on tax controversy and Internal Revenue Service (IRS) administrative matters. She also counsels professional services firms, investment fund managers, and private equity firms on partnership tax issues. With decades of experience spanning government service, a “Big Four” public accounting firm, and in-house as the director of tax controversy for a large multinational corporation, Jennifer offers a rare perspective in her invaluable ability to see tax issues from multiple vantage points.

The Hon. Elizabeth A. Copeland, Judge | United States Tax Court

Judge Copeland was born in Colorado. She earned her Bachelor of Business Administration, cum laude, from the University of Texas at Austin, and her Juris Doctor from the University of Texas School of Law. A Certified Public Accountant (Texas, 1988), she was admitted to the State Bar of Texas in 1992.

Diana L. Erbsen, Esq., Partner | DLA Piper

Diana Erbsen has more than two decades of experience in tax controversy, representing clients in all aspects of sophisticated, challenging, and often high stakes tax disputes. In 2014, Diana was appointed to the position of Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice by President Obama. Following the end of the administration on January 20, 2017, Diana returned to DLA Piper as a partner.

Daniel N. Price, Esq. | Law Offices of Daniel N. Price

Dan’s legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Dan has had unique experience with tax controversy and tax administration. In February 2025, the American College of Tax Counsel elected Dan as a fellow (see press release) recognizing his experience practicing tax law.

Kaitlyn Loughner, Esq., CPA, Partner | Frost Law

Kaitlyn’s experience as a Certified Public Accountant and a tax attorney gives her a unique perspective on domestic and international tax compliance issues for individuals and businesses including streamlined compliance for individuals, corporations, partnerships, and limited liability companies. Kaitlyn handles cases with issues involving individual and corporate income tax, international tax compliance, IRS and State tax audits, tax relief and collection — including sales and use taxes, admissions and amusement tax, and withholding tax.

Guinevere M. Moore, Esq., Managing Member | Moore Tax Law Group

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies. She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with an office in Chicago.

Carlos F. Ortiz, Esq., Partner | BakerHostetler

A seasoned trial attorney, recognized by Law360 as a “Legal Lion of the Week” and by AmLaw’s Litigation Daily as a “Litigator of the Week,” Carlos Ortiz focuses his practice on high-risk tax controversies, anti-corruption (Foreign Corrupt Practices Act (FCPA) and Foreign Extortion Protection Act (FEPA)), offshore tax issues, anti-money laundering, e-commerce fraud and healthcare fraud, as well as allegations of fraud against government agencies and financial institutions. He has extensive experience representing U.S.- and foreign-based corporations and individuals in the pharmaceutical, financial services, healthcare, aerospace, energy and telecommunications industries in connection with matters before enforcement and regulatory agencies, including the U.S. Department of Justice (DOJ), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC) and various state attorneys general. Over his career in private practice, he has secured the declination of criminal charges for corporate and individual clients. On several occasions, he has prevented the referral of charges for the target of criminal tax investigations.

Rod J. Rosenstein, Esq., Partner | King & Spalding

As Deputy Attorney General under President Donald J. Trump, Rod J. Rosenstein supervised all Department of Justice components. He also held senior political appointments under Presidents George W. Bush and Barack Obama, as U.S. Attorney for Maryland from 2005 to 2017 and Principal Deputy Assistant Attorney General for the Tax Division from 2001 to 2005. A skilled trial and appellate lawyer, Rod personally represented the United States in 23 jury trials and argued 21 civil and criminal appeals in appellate courts and the Supreme Court. He helps clients with sensitive regulatory, enforcement and litigation challenges, including civil and criminal cases, congressional investigations, crisis management, national security and cyber issues, higher education inquiries, tax controversies, and compliance matters.

Don Fort, CPA, Director of Investigations | Kostelanetz

John D. (Don) Fort is the Director of Investigations at Kostelanetz LLP, and the former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and has an extensive network of connections both within the government and in private industry.

Guy Ficco, Chief, Criminal Investigation Division | Internal Revenue Service

Guy Ficco has been serving as the Chief of the IRS Criminal Investigation (CI) Division since April 1, 2024. A 29-year veteran of the IRS, Ficco began his career in 1995 as a student co-op in the New York Field Office. Over the years, he has held numerous leadership positions, including Deputy Chief of CI, Executive Director of Global Operations, and Special Agent in Charge of the Philadelphia Field Office. He is a Certified Fraud Examiner and holds a bachelor’s degree in business administration with a concentration in accounting from Dominican University in New York.

Ian M. Comisky, Esq., Partner | Fox Rothschild

Ian has more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense, and complex corporate and commercial disputes.

Jenny G. Sugar, Esq., Member | Moore & Van Allen

Jenny Sugar is a member of Moore & Van Allen’s Litigation group. She represents corporations and executives in white collar criminal and government enforcement investigations, proceedings, and trials.

As a federal prosecutor for more than two decades, Jenny investigated, prosecuted, and oversaw matters involving a broad range of complex financial crimes, including investment fraud, bank fraud, wire fraud, tax fraud, Ponzi schemes, money laundering, and abuse of government funding programs, as well as health care fraud matters.

Dean Zerbe, Esq. Partner | Zerbe, Miller, Fingeret, Frank & Jadav

Dean Zerbe was Senior Counsel and Tax Counsel for the Chairman of the Senate Finance Committee, Senator Charles E. Grassley, 2001-2008. At the direction of Chairman Grassley, Dean was the counsel responsible for the modern IRS whistleblower law – signed into law in 2006 — which established the IRS Whistleblower Office and created an award program for tax whistleblowers. Dean “wrote the law” when it comes to the IRS whistleblower office and reward program.

Randall M. Fox, Esq., Partner | Kirby McInerney

Randall M. Fox is a partner in our New York office who represents whistleblowers in False Claims Act and IRS, SEC, and CFTC matters about tax, healthcare, procurement, and investment frauds. He was named the Whistleblower Lawyer of the Year for 2021 by The Anti-Fraud Coalition.

Larry A. Campagna, Esq., Managing Shareholder | Chamberlain, Hrdlicka, White, Williams & Aughtry, PC

Larry Campagna has an established reputation as an authoritative litigator in matters of business litigation, white-collar criminal defense, and particularly in federal, state and local tax controversies. For more than 45 years, he has resolved thousands of civil and criminal litigation matters, many of which involved sophisticated and complex legal issues that established precedent in courts at the federal, state and local levels.

Erin M. Collins, Esq., National Taxpayer Advocate | Internal Revenue Service

In March 2020, Erin M. Collins was appointed by Secretary Mnuchin as the National Taxpayer Advocate and she now oversees the Office of the Taxpayer Advocate Service (TAS). She is the “Voice of the Taxpayer” within the IRS and before Congress. TAS serves as a “safety net” for taxpayers by advocating for resolution of individual and business taxpayer issues within the IRS. She identifies and works toward systemic changes for all taxpayers while protecting Taxpayer Rights. TAS also oversees the Low Income Taxpayer Clinic (LITC) federal grant program and the Taxpayer Advocacy Panel (TAP). As part of her Annual Report to Congress, she makes administrative and legislative changes to protect taxpayer rights and works toward improving the quality of taxpayer service and tax administration by being an independent voice inside the IRS. As the National Taxpayer Advocate, Erin testifies before the Senate Finance Committee, the U.S. House of Representatives Ways and Means Committee Oversight Subcommittee, and the Senate Appropriations Subcommittee on topics concerning tax administration and taxpayer rights.

E. Martin Davidoff, CPA, Esq., Partner-in-Charge | National Tax Controversy Practice, Prager Metis

E. Martin Davidoff, CPA, Esq., brings over 30 years of experience as both an accountant and attorney. He has authored 30 articles in CPA Magazine, serving as its IRS Representation Advisor. He is the founder of accounting and law firms dedicated primarily to taxes, tax advice, and tax preparation, with a mission to provide clients with peace of mind. Martin currently serves as the National Managing Partner of the Tax Controversy team at Prager Metis CPAs, LLC. For more information, please visit his websites.

Robert J. Fedor, Esq., Managing Member | Robert J. Fedor, Esq. LLC

Managing Member since 1995.

With over 35 years of experience in representing businesses and individuals before all types of Internal Revenue Service proceedings, whether it be administrative or before the United States Bankruptcy Court, the United States Tax Court, one of the United States District Courts or a U.S. Court of Appeals, Robert J. Fedor leads this 8-member firm with his expertise in tax and tax-related matters. Mr. Fedor’s experience has provided him with a vast understanding of tax-related issues, spanning from tax litigation, IRS collections, criminal tax defense, as well as other tax-related controversy matters.

The Hon. Jennifer E. Siegel, Special Trial Judge | United States Tax Court

Special Trial Judge Siegel holds a B.A. from Barnard College, an M.B.A. from the Drucker School of Management at Claremont Graduate University, a J.D. from the University of San Francisco School of Law, and an LL.M. in Taxation from New York University School of Law.

Moderator: Andrew Weiner, Esq., Counsel | Kostelanetz

Andrew Weiner, Esq., is Counsel at Kostelanetz LLP in Washington, D.C., specializing in civil and criminal tax controversies at all stages of the administrative and judicial process. He has handled a wide range of matters, including partnership taxation, corporate taxation and reorganizations, taxation of S corporations, tax accounting methods, income tax, gift and estate taxes, and collections. Prior to joining Kostelanetz, Mr. Weiner served for nearly 11 years as a trial attorney with the U.S. Department of Justice Tax Division, where he briefed and argued approximately 50 cases before the United States courts of appeals and handled several significant matters in the Court of Federal Claims focused on tax shelters, research and energy credits, FBAR penalties, and Administrative Procedure Act claims. During his time at the Department of Justice, he received the Tax Division’s Outstanding Attorney Award five times and was awarded a Special Commendation.

David W. Foster, Esq., Partner | Kirkland & Ellis

David W. Foster, P.C., is a Partner in the Tax Disputes Practice Group at Kirkland & Ellis LLP in Washington, D.C. He advises a diverse clientele—including large corporations, private equity firms, hedge funds, partnerships, estates, exempt organizations, and individuals, many of whom are subject to the IRS’s Global High Wealth initiative. His practice encompasses a wide array of tax issues, including BBA partnership audit and litigation procedures, energy tax credits, international tax and transfer pricing, challenges to tax-exempt status, taxation of financial products, estate and gift taxes, deferred compensation, voluntary disclosures, and criminal tax matters.

Katherine Jordan, Esq., Director of Tax Controversy | GBX Group

Katherine Jordan, Esq., serves as the Director of Tax Controversy at GBX Group LLC, a Cleveland-based firm specializing in historic real estate redevelopment. In this role, she oversees the company’s federal tax audits, appeals, and litigation, ensuring compliance with federal tax laws.

Michele F.L. Weiss, Esq., Principal | Holtz, Slavett & Drabkin

Michele F.L. Weiss, Esq., is a Principal at Holtz, Slavett & Drabkin, APLC, a tax controversy and litigation law firm based in Los Angeles, California. With over 20 years of experience, she specializes in representing clients in civil and criminal tax matters before federal, state, and local tax authorities, including the IRS, California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA), Employment Development Department (EDD), Board of Equalization, Office of Tax Appeals (OTA), County Assessor, and Los Angeles City Finance Office.

Moderator: Sanford J. Boxerman, Esq., Shareholder | Neill Schwerin Boxerman, PC

Sanford J. Boxerman, Esq., is a founding shareholder of Neill Schwerin Boxerman, P.C., a boutique law firm in St. Louis, Missouri, specializing in tax controversy, white-collar criminal defense, and digital assets. He represents individuals and corporations in federal courts nationwide, handling complex civil and criminal tax matters, white-collar investigations and prosecutions, and advising clients in the cryptocurrency and blockchain sectors.

Niles A. Elber, Esq., Member | Caplin & Drysdale, Chartered

Niles A. Elber, Esq., is a Member at Caplin & Drysdale, Chartered, in Washington, D.C., with over 20 years of experience in civil and criminal tax controversies. His practice encompasses IRS examinations, appeals, collections, and federal court proceedings, as well as administrative and grand jury tax investigations. He has significant experience advising clients on offshore compliance matters, including voluntary disclosures and FBAR penalty examinations related to unreported foreign bank accounts.

Carolyn A. Schenck, Esq., National Fraud Counsel and Senior Level Counsel (Offshore), Office of Chief Counsel | Internal Revenue Service

Carolyn A. Schenck, Esq., serves as the National Fraud Counsel and Senior Level Counsel (Offshore) in the Office of Chief Counsel at the Internal Revenue Service (IRS) in Washington, D.C. In this capacity, she provides legal guidance on complex civil fraud issues and offshore compliance matters, collaborating with IRS divisions such as Small Business/Self-Employed and Large Business & International.

Jeremy H. Temkin, Esq., Principal | Morvillo Abramowitz Grand Iason & Anello PC

Jeremy H. Temkin, Esq., is a Principal at Morvillo Abramowitz Grand Iason & Anello PC in New York, specializing in white-collar criminal defense, government investigations, and tax controversy matters. He has extensive experience representing individuals and corporations in criminal, regulatory, and civil matters in state and federal courts and before arbitration panels. His practice includes handling high-profile tax and securities fraud cases, conducting internal investigations for public corporations, and serving as Independent Examiner for numerous banks participating in the Department of Justice’s Swiss Bank Program. He regularly advises clients on tax compliance issues and represents taxpayers and professionals in investigations conducted by the IRS, DOJ, and state taxing authorities.

Moderator: Carmela G. Walrond, Esq., Partner | JLD Tax Resolution Group

Carmela G. Walrond, Esq., is a Partner at JLD Tax Resolution Group in Union City, New Jersey. She is an experienced tax attorney and accountant who has assisted clients in saving millions of dollars in back taxes through various methods, including the IRS Offer in Compromise program, penalty abatement, and audit representation. She is licensed to practice in federal and state Tax Courts, as well as bankruptcy court (Chapter 7), and has handled cases for individuals and small businesses throughout New York and New Jersey.

Yvonne R. Cort, Esq., Partner | Capell Barnett Matalon & Schoenfeld

Yvonne R. Cort is a Partner at Capell Barnett Matalon & Schoenfeld LLP, where she specializes in resolving federal and New York State tax controversies. With over two decades of experience, she represents individuals and businesses in matters including IRS and NYS audits, appeals, residency audits, unfiled returns, income tax, sales tax, withholding tax, responsible person assessments, liens and levies, tax warrants, innocent spouse relief, voluntary disclosures, installment agreements, and offers in compromise.

Sally Reddy, Esq., Attorney | The Law Office of Sally Reddy

Sally Reddy, Esq., is a Principal Attorney at Dallo Law Group, a boutique tax law firm based in San Diego, California. With over a decade of experience, she specializes in tax dispute resolution, complex tax planning, estate planning, and probate matters. Her practice encompasses representation in IRS, California Franchise Tax Board (FTB), Employment Development Department (EDD), and California Department of Tax and Fee Administration (CDTFA) audits and collections.

Jeffrey M. Sklarz, Esq., Founding Partner | Green & Sklarz

Jeffrey M. Sklarz, Esq., is a Founding Partner at Green & Sklarz LLC, a boutique law firm based in New Haven, Connecticut. With over two decades of experience, he specializes in complex financial litigation, including bankruptcy, creditor/debtor disputes, tax controversies, pension and employee benefit litigation, and commercial litigation. He regularly represents clients in both state and federal courts and has a particular focus on the intersection of bankruptcy, tax, and ERISA law.

Moderator: Tom Greenaway, Esq., Designated Principal | KPMG Law US

Tom Greenaway, Esq., serves as the Designated Principal of KPMG Law US, a subsidiary of KPMG LLP established in 2025 to provide legal services in the United States under Arizona’s Alternative Business Structure (ABS) framework. This initiative positions KPMG as the first of the Big Four accounting firms to offer legal services in the U.S., integrating legal capabilities with KPMG’s extensive tax, advisory, and technological resources .

Anna Tavis, Esq., Staff Attorney | Brooklyn Legal Services

Anna Caroline Tavis, Esq., is a Staff Attorney at Brooklyn Legal Services, where she specializes in representing low-income taxpayers in disputes with the IRS and New York State tax authorities. Her work focuses on ensuring equitable access to tax justice for underserved communities, particularly immigrants and individuals with limited English proficiency.
Kathy A. Enstrom, MB

Kathy A. Enstrom, MBA, EA, Director of Investigations | Moore Tax Law Group

Kathy A. Enstrom, MBA, EA, serves as the Chief Operating Officer and Director of Investigations at Moore Tax Law Group, LLC, based in Chicago, Illinois. She brings nearly three decades of federal law enforcement experience, primarily from her tenure with the Internal Revenue Service Criminal Investigation (IRS CI) division, where she held several executive positions.

Sarah Green, Esq., Senior Managing Associate | Dentons Sirote

Sarah Green, Esq., is a Senior Managing Associate at Dentons Sirote, based in the firm’s Huntsville, Alabama office. As a member of the Tax practice group, she concentrates on federal and state tax controversy and litigation, representing clients through all phases of disputes, including IRS audits, administrative appeals, and proceedings before the U.S. Tax Court, federal district courts, and U.S. Courts of Appeals.

James M. Bandoblu, Jr., Esq., Managing Partner | Hodgson Russ

James M. Bandoblu Jr., Esq. serves as the Managing Partner of Hodgson Russ LLP’s Palm Beach, Florida office. He leads the firm’s Federal Tax Controversy Practice, focusing on a wide range of domestic and international tax matters.

Moderator: S. Starling Marshall, Esq., Partner | Crowell & Moring

S. Starling Marshall, Esq. is a Partner at Crowell & Moring LLP in New York, where she co-chairs the firm’s Tax Group and is a member of the Litigation Group. With over 15 years of experience, she specializes in federal tax controversy, complex IRS audits, administrative appeals, and litigation before federal and state courts, arbitration panels, and administrative tribunals.

Tino M. Lisella, Esq., Shareholder | Carlton Fields

Tino M. Lisella, Esq. is a Shareholder at Carlton Fields, based in the firm’s West Palm Beach, Florida office. His practice focuses on securities enforcement, civil and criminal tax controversy, and white-collar litigation.

Laura E. Krebs Al-Shathir, Esq., Shareholder | Capes Sokol, PC

Laura E. Krebs Al-Shathir, Esq. is a Shareholder at Capes Sokol, P.C., based in St. Louis, Missouri. She specializes in tax and corporate law, offering comprehensive counsel to a diverse clientele that includes multinational corporations, small businesses, limited liability companies, S corporations, and nonprofit organizations.

Barbara T. Kaplan, Esq., Shareholder | Greenberg Traurig

Barbara T. Kaplan, Esq. is a Shareholder at Greenberg Traurig, LLP, where she serves as Co-Chair of the Global Tax Practice and Chair of the New York Tax Practice. With over four decades of experience, Ms. Kaplan focuses her practice on federal, state, and local tax examinations, controversies, and litigation, including administrative and grand jury criminal tax investigations.

Moderator: Frank Agostino, Esq., Founder & President | Agostino & Associates, PC

Frank Agostino, Esq. is the founder and president of Agostino & Associates, P.C., a law firm based in Hackensack, New Jersey, specializing in civil and criminal tax controversies. With over four decades of experience, Mr. Agostino has established himself as a leading authority in tax law, representing clients before the Internal Revenue Service (IRS) and state taxing authorities.

Caitlin R. Tharp, Esq. Associate | Steptoe

Caitlin R. Tharp, Esq. is an Associate at Steptoe LLP in Washington, D.C., where she specializes in federal tax controversy and litigation. Her practice encompasses all stages of tax disputes, including IRS examinations, administrative appeals, and litigation before the U.S. Tax Court, Court of Federal Claims, federal district courts, and appellate courts. Ms. Tharp has experience examining witnesses at trial and deposition, and she has authored numerous motions and briefs.

Travis W. Thompson, Esq., Counsel | Boutin Jones

Travis W. Thompson, Esq. is Counsel at Boutin Jones Inc. in Sacramento, California, where he specializes in federal and state tax controversy and litigation. His practice encompasses representing individuals, corporations, partnerships, limited liability companies, and trusts and estates in various tax matters.

Erin R. Hines, Esq., Partner | Akerman

Erin R. Hines, Esq. is a Partner in the Tax Practice Group at Akerman LLP’s Atlanta office, specializing in federal tax controversy and litigation. With over a decade of experience, she represents clients in IRS examinations, administrative appeals, and litigation before various federal courts, including the U.S. Tax Court and U.S. District Courts.

Moderator: Justin L. Campolieta, Partner | Jones Day

Justin L. Campolieta, Esq. is a Partner in the Tax Practice at Jones Day, based in the firm’s New York office. He brings nearly two decades of experience from the Internal Revenue Service (IRS) Office of Chief Counsel, where he held several senior roles, including Senior Level Special Trial Attorney in the Strategic Litigation division.

Sarah E. Paul, Esq., Partner | Eversheds Sutherland

Sarah E. Paul, Esq. is a Partner at Eversheds Sutherland in New York, where she serves on the firm’s Executive Committee and co-leads the Global Corporate Crime and Investigations practice. Her practice encompasses white-collar defense, government and internal investigations, cross-border compliance, and federal tax controversy.

Andrew Strelka, Esq., Counsel | Latham & Watkins

Andrew Strelka, Esq. serves as Counsel in the Tax Practice at Latham & Watkins LLP’s Washington, D.C. office. He brings extensive experience from both government service and private practice, focusing on federal tax litigation, enforcement, and regulatory matters.

Lisandra Ortiz, Esq., Member, Miller & Chevalier | Chartered

Lisandra Ortiz, Esq. is a Member at Miller & Chevalier Chartered in Washington, D.C., where she focuses her practice on federal tax controversy matters, particularly those related to international tax and transfer pricing.

DAY 1, THURSDAY, JUNE 26, 2025

WELCOME – OPENING REMARKS | 8:00am – 8:05am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I | 8:05am – 8:30am

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the Internal Revenue Service (IRS) and Justice Department (DOJ) have been pursuing new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. In recent weeks, however, the future and efficacy of those programs have been called into question as resource constraints are being imposed across the federal government. These panels, including three afternoon breakout sessions, provide a comprehensive update on developments and priorities across various functions of the Treasury Department, Justice Department Tax Division and IRS relating to enforcement of and compliance with our Nation’s tax laws.

Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC

Michael J. Desmond, Esq., Member and Co-Chair of Tax Controversy Group, Miller & Chevalier, Chartered, Washington, DC

WHAT’S NEXT FOR THE IRS? A BUDGET AND POLICY PERSPECTIVE | 8:30am – 9:20am

At our 2024 program, the IRS’ Operating Division Commissioners provided an update on a new leadership structure at the IRS designed to align its enforcement priorities with a surge in funding provided for under the Inflation Reduction Act. That enforcement focus has since flipped, with a turnover in leadership, a major curtailment of funding and staff, and projections for further material resource reductions. The future of IRS enforcement is now tied up with broader legislative priorities, including extension of the individual and various expiring business provisions of the Tax Cuts and Jobs Act and an uncertain future for the IRS. Meanwhile, the rest of the world is rapidly moving forward with implementation of the Organization for Economic Co-operation and Development’s (OECD) Global Anti-Base Erosion Rules (GloBE) (Pillar 2), with the United States sitting on the sidelines for the moment on these global tax initiatives. Our panel of experts all work at the intersection of tax administration and policy and they provide insight on what the future might hold for tax enforcement, both domestically and around the world.

Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY

Loren C. Ponds, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, Washington, DC

Scott Levine, Esq., Former Deputy Assistant Secretary, International Tax Affairs, Washington, DC

Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC

Terry Lemons, Former Communications & Liaison Chief, Internal Revenue Service, Washington, DC

Break | 9:20am – 9:30am

UPDATE FROM THE IRS INDEPENDENT OFFICE OF APPEALS | 9:30am – 9:55am

The IRS Independent Office of Appeals (Appeals) has always served a critical role in resolving tax disputes short of litigation, considering hazards of litigation for taxpayers and the IRS alike. Over the past two years, Appeals has been calibrating a renewed focus on alternative dispute resolution (ADR) procedures as a tool to complement its traditional conference procedures. In the current resource constrained environment, with a large inventory of complex cases pending in Exam, Appeals and in litigation, Appeals in general and ADR programs in particular are likely to play an increasingly important role in minimizing delay in dispute resolution. The Chief of IRS Appeals has been invited to give her perspective on ADR and to provide an update on Appeals activities in general.

Moderator: Emily P. Hughes, PC, Esq., Partner, Kirkland & Ellis, Washington, DC

Elizabeth Askey, Esq., Chief, IRS Independent Office of Appeals, Washington, DC (invited)

Break | 9:55am – 10:05am

UPDATE FROM THE U.S. TAX COURT AND THE IRS OFFICE OF CHIEF COUNSEL | 10:05am – 10:50am

The Tax Court and IRS Office of Chief Counsel sit at the center of tax controversy, with more than 25 thousand pending cases that range from multibillion dollar transfer pricing disputes to collection due process matters with relatively small amounts at stake but often presenting important questions of law. Decisions from the Tax Court have broad consequences across the federal tax system. This panel provides insight into cases pending with the Tax Court and matters being worked by Chief Counsel that may be on their way to the Court. The Deputy Chief Counsel (Operations) has also been invited to provide an update on Counsel activities including litigation in Tax Court, prospects for case resolution in a resource constrained environment and the role of field counsel attorneys in advising Exam, Appeals and other IRS functions

Moderator: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC

The Hon. Elizabeth A. Copeland, Judge, United States Tax Court, Washington, DC (invited)

Audrey M. Morris, Esq., Deputy Chief Counsel (Operations), Office of Chief Counsel, Internal Revenue Service, Washington, DC (invited)

Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY

Break | 10:50am – 11:00am

PSYCHOLOGY AND TAX ENFORCEMENT | 11:00am – 12:00pm

Psychological issues are an often-overlooked factor in many tax disputes, particularly but not only for individual taxpayers. These issues often create or magnify tax compliance problems such as non-filing, non-payment, and an impaired ability to interact with the IRS to resolve or address a tax dispute. Properly explained and understood, these issues can also provide a basis for penalty relief, late filing relief, late election relief, and other relief. This panel considers the impact of psychological issues on tax compliance and enforcement, including the use of experts.

Moderator: Daniel N. Price, Esq., Law Offices of Daniel N. Price, San Antonio, TX

Kaitlyn Loughner, Esq., CPA, Partner, Frost Law, Annapolis, MD

Guinevere M. Moore, Esq., Managing Member, Moore Tax Law Group, Chicago, IL

Carlos F. Ortiz, Esq., Partner, BakerHostetler, New York, NY

Russell Wade, Psychotherapist, Russell l Wade, ACSW LICSW, Washington, DC

Lunch | 12:00pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK III

THE IMPACT OF LOPER BRIGHT ON TAX COMPLIANCE AND ENFORCEMENT

The scope and complexity of tax legislation requires interpretation and implementation through regulations and other guidance, with extensive “priority guidance” plans published by Treasury and the IRS each year to identify areas of specific focus based on stakeholder input. The treatment of tax regulations by the courts, including the level of deference provided to those regulations, has evolved significantly in recent years, most recently with the Supreme Court’s 2024 decision in Loper Bright, which mandated that the more deferential “any reasonable interpretation” of a statute standard that had existed for 30 years under the Court’s 1984 Chevron decision be replaced with a requirement that regulations only be sustained if they are the “best” interpretation of the relevant standard. This panel explores the meaning and impact of the Loper Bright decision and provides insight on where and how practitioners should consider regulatory deference issues in handling tax disputes.

Moderator: Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC

David W. Foster, Esq., Partner, Kirkland & Ellis, Washington, DC

Katherine Jordan, Esq., Director of Tax Controversy, GBX Group, Cleveland, OH

Michele F.L. Weiss, Esq., Principal, Holtz, Slavett & Drabkin, Los Angeles, CA

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

TRACK III

NAVIGATING JOHN DOE SUMMONSES

John Doe summons can provide the IRS with an important enforcement tool to obtain the names and other information for taxpayers thought to be worthy of examination or inquiry through a source other than return filings. John Doe summonses have their own unique procedural requirements and attributes, including judicial review and suspension of the assessment limitations period. They can raise particular challenges and concerns when issued to law firms and others where privilege and other important considerations can come into play. This panel reviews recent cases in which John Does summonses have been issued and authorized by the courts and considers some of the issues and challenges presented in those cases, including for both the persons receiving the summonses and the taxpayers whose information is being sought, all to provide insight and tips from practitioners as to how to handle them.

Moderator: Sanford J. Boxerman, Esq., Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO

Niles A. Elber, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC

Carolyn A. Schenck, Esq., National Fraud Counsel and Senior Level Counsel (Offshore), Office of Chief Counsel, Internal Revenue Service, Washington, DC (invited)

Jeremy H. Temkin, Esq., Principal, Morvillo Abramowitz Grand Iason & Anello PC, New York, NY

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20pm – 4:10pm

TRACK III

HANDLING DISPUTED TAX ISSUES IN BANKRUPTCY

Federal bankruptcy courts can provide an alternative path to the Tax Court and refund forums for taxpayers to contest tax liabilities. Taxpayers may, however, have little control over the timing of a bankruptcy filing and the filing itself, driving unique considerations in bankruptcy including around the dischargeability of taxes, which is often a function of timing. As added complexity, older and open tax years may be in very different procedural postures at the time of a bankruptcy filing, with some years may be under IRS examination and other in administrative appeals or in litigation. Due to the unique treatment of taxes in bankruptcy, including as a potential priority claim, the IRS’s interests in a case may be more adversarial to other creditors than to the taxpayer itself. This panel considers and provides insight on the unique aspects of adjudicating tax disputes in bankruptcy.

Moderator: Carmela G. Walrond, Esq., Partner, JLD Tax Resolution Group, Union City, NJ

Yvonne R. Cort, Esq., Partner, Capell Barnett Matalon & Schoenfeld, Syosset, NY

Sally Reddy, Esq., Attorney, The Law Office of Sally Reddy, San Diego, CA

Jeffrey M. Sklarz, Esq., Founding Partner, Green & Sklarz, New Haven, CT

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30pm – 5:30pm

TRACK III

CORRECTING THE RECORD: PATHS TO COMPLIANCE

In filing tax returns and making other submissions to the IRS mistakes happen, particularly as the tax law grows more complex. Some errors are discovered by taxpayers, others by auditors and others. Often, errors are identified in connection with the preparation of a subsequent year’s return or in connection with an IRS examination. Taxpayers and their advisors typically want to be forthcoming and transparent, knowing that self-identification and correction can mitigate exposure. This panel explores opportunities to fix mistakes, discuss strategic considerations, and provide practical guidance.

Moderator: Tom Greenaway, Esq., Designated Principal, KPMG Law US, Tempe, AZ

Anna Tavis, Esq., Staff Attorney, Brooklyn Legal Services, Brooklyn, NY

Kathy A. Enstrom, MBA, EA, Director of Investigations, Moore Tax Law Group, Chicago, IL

Sarah Green, Esq., Senior Managing Associate, Dentons Sirote, Birmingham, AL

James M. Bandoblu, Jr., Esq., Managing Partner, Hodgson Russ, Palm Beach, FL

DAY2, FRIDAY, JUNE 27, 2025

TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II | 8:30am – 8:55am

UPDATE FROM THE TAX DIVISION, US DEPARTMENT OF JUSTICE

The Tax Division is going through a historic change in leadership and is the subject of ongoing discussions on its role and placement in tax administration. Meanwhile, along with other federal agencies, the Tax Division is dealing with a curtailment of resources while also absorbing an increase in the number of tax cases filed in refund, bankruptcy and other courts around the country. The Tax Division is also responsible for representing the United States in the various courts of appeal on cases involving tax at a dynamic time for important issues such as the standard for review of agency rulemaking. This interview provides an update on these and other important topics.

Moderator: Rod J. Rosenstein, Esq., Partner, King & Spalding, Washington, DC

Representative, Tax Division, US Department of Justice, Washington, DC (to be invited)

Break | 8:55am – 9:05am

CRIMINAL TAX ENFORCEMENT UPDATE | 9:05am – 10:05am

Criminal tax cases impact tax enforcement and administration far beyond the cases charged and tried every year, sending a signal to taxpayers and practitioners of areas of compliance that are a particular focus for the IRS. In a resource constrained environment, this signal could be more important than ever, as practitioners gage the future of tax compliance and enforcement. This panel provides inside perspective on the status of IRS criminal investigations and what to expect going forward.

Moderator: Don Fort, CPA, Director of Investigations, Kostelanetz, Washington, DC

Guy Ficco, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC (invited)

Representative, Tax Division, US Department of Justice, Washington, DC (to be invited)

Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA

Jenny G. Sugar, Esq., Member, Moore & Van Allen, Charlotte, NC

Break | 10:05am – 10:20am

IRS WHISTLEBLOWER OFFICE UPDATE | 10:20am – 10:45am

With the enactment of recent changes to section 7623, claims for whistleblower awards have skyrocketed and the IRS Whistleblower Office has a full plate of work: processing new submissions; managing open claims and issuing awards. To ensure it is successfully meeting these challenges, the Whistleblower Office has embarked on an ambitious Whistleblower Program Improvement Plan. Key goals of the plan include: increasing high-value claims coming in; improving the Whistleblower’s Office ability to identify such claims; and better tracking of such claims through improved systems—and efforts to pay awards sooner. This panel provides an update from the IRS Whistleblower Office on recent reform efforts, highlights issues that the IRS is particularly interested in hearing more about from whistleblowers, what makes for a good whistleblower submission, as well as touches on recent court decisions addressing this important practice area.

Moderator: Dean Zerbe, Esq. Partner, Zerbe, Miller, Fingeret, Frank & Jadav, Houston, TX

John W. Hinman, Director, Whistleblower Office, Internal Revenue Service, Washington, DC (invited)

Randall M. Fox, Esq., Partner, Kirby McInerney, New York, NY

Break | 10:45am – 10:55am

TAXPAYER ADVOCATE UPDATE | 10:55am – 11:25am

Erin Collins became the National Taxpayer Advocate (“NTA”) on March 30, 2020, at the outset of the COVID-19 pandemic. With the IRS pushed to its breaking point by the pandemic and now facing the challenge of a resource constrained environment), Collins and her team continue their dual focus on addressing systemic issues (of which there are many) and handling individual taxpayer cases (of which there are many more). Hear about the lessons learned over Collins’ past five years in the role and her vision for the future of the Taxpayer Advocate Service.

Moderator: Larry A. Campagna, Esq., Managing Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Houston, TX

Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC (invited)

Break | 11:25am – 11:40am

IRS COLLECTION UPDATE | 11:40am – 12:20pm

Issuance of IRS collection notices have resumed and IRS collection efforts from high income non-filers and those with outstanding tax debt have brought in millions of dollars since FY 2023. This panel provides an update from IRS Collection on recent collection efforts, availability of new collection tools and expectations for the future that impacts every tax practice.

Moderator: E. Martin Davidoff, CPA, Esq., Partner-in-Charge – National Tax Controversy Practice, Prager Metis, Cranbury, NJ

Robert J. Fedor, Esq., Managing Member, Robert J. Fedor, Esq., Cleveland, OH

The Hon. Jennifer E. Siegel, Special Trial Judge, United States Tax Court, Washington, DC (invited)

Lunch | 12:20pm – 1:30pm

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK III

THE BENEFITS AND DETRIMENTS OF USING ARTIFICIAL INTELLIGENCE IN TAX PRACTICE

What exactly is Artificial Intelligence (AI) and how will AI impact tax practice in the future? Join us for an AI demonstration, while we explore the types of AI that are currently available and how they differ from each other. Panelists also address how the IRS is using AI in its enforcement efforts and what tax practitioners should be aware of under Circular 230 and the ABA Model Rules.

Moderator: Frank Agostino, Esq., Founder & President, Agostino & Associates, PC, Hackensack, NJ

Caitlin R. Tharp, Esq. Associate, Steptoe, Washington, DC

Travis W. Thompson, Esq., Counsel, Boutin Jones, Sacramento, CA

Erin R. Hines, Esq., Partner, Akerman, Atlanta, GA

Break | 3:30pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK III

CIVIL TAX LITIGATION

Recently decided and pending tax cases provide a window into the IRS’s enforcement priorities and the types of issues giving rise to disputes with taxpayers that may be difficult to resolve on audit, in appeals or through other means. This panel reviews a number of recently decided cases and considers several pending cases for insight on areas of civil tax controversy.

Moderator: Justin L. Campolieta, Partner, Jones Day, New York, NY

Sarah E. Paul, Esq., Partner, Eversheds Sutherland, New York, NY

Andrew Strelka, Esq., Counsel, Latham & Watkins, Washington DC

Lisandra Ortiz, Esq., Member, Miller & Chevalier, Chartered, Washington, DC

Representative(s), Tax Division, US Department of Justice and/or IRS Office of Chief Counsel, Washington, DC (to be invited)