This comprehensive, full-day event features panels with private practitioners and government employees from the Internal Revenue Service and Department of Justice Tax Division covering a myriad of hot topics that practitioners need to be familiar with when representing clients before the IRS. The focus is on the practical issues and how to handle them rather than theoretical issues.
This course is co-sponsored with myLawCLE.
Key topics to be discussed:
Knock-Knock: What to Do When Special Agents Are At Your Door
The Unfolding of a Criminal Tax Case
Day of Reckoning: The Federal Sentencing
Enforcement Trends: What’s Hot and What’s Not
Wages vs Distribution: What is Reasonable Compensation?
Hidden Assets and Fraudulent Transfers: What Accountants Need To Watch For!
Ethical Practice & The Dangers of Getting Too Close to Clients
IRS Enforcement Around Employee Retention Credits
Appealing the Denied Offer
Date / Time: November 30, 2023
1:00 pm – 4:00 pm Eastern
12:00 pm – 3:00 pm Central
11:00 am – 2:00 pm Mountain
10:00 am – 1:00 pm Pacific
Date / Time: December 1, 2023
8:30 am – 5:00 pm Eastern
7:30 am – 4:00 pm Central
6:30 am – 3:00 pm Mountain
5:30 am – 2:00 pm Pacific
Sara V. Spodick, Esq | Quinnipiac University Law School
Director of the Tax Clinic
BA, Southern Connecticut State University
JD, Quinnipiac University
LAWS 612 Advanced Tax Clinic
Law Summer 2023
LAWS 694 Tax Clinic Seminar
Law Fall 2023
Philip J. Wilson, CPA | Marcum, LLP
Philip Wilson is office managing partner of Marcum’s Costa Mesa, California, office and is leader of the Firm’s national Tax Controversy group. Mr. Wilson has more than 30 years of CPA and business advisory experience, including experience as an IRS revenue agent.
Mr. Wilson focuses on helping individuals and companies resolve tax controversies with the Internal Revenue Service, representing all types of businesses as well as high net worth individuals.
Prior to joining Marcum, Mr. Wilson was a founding partner of WilsonMorgan LLP, based in Irvine. He oversaw all of the firm’s tax compliance, tax consulting, and tax controversy engagements. He has substantial experience in the real estate area, including tax structuring for commercial and residential developers, and has worked with clients in a wide variety of industries.
Damon Rowe joins Meadows Collier after two decades of service at the IRS. His practice focus is White-Collar Crime, Tax Controversy and Government Regulatory Litigation. He has expertise in many areas including cryptocurrency, financial crimes, civil and criminal tax, money laundering, fraud, internal investigations and the Bank Secrecy Act.
Mr. Rowe began his career at the IRS in 1998 as a Special Agent and held numerous leadership positions for the agency. He served as the Special Agent in Charge for both the Los Angeles and Dallas Field Offices in the Criminal Investigation Division. This office investigates a diverse mix of financial investigations, including cybercrime, international tax fraud, identity theft, public corruption and Bank Secrecy Act. His next leadership position was Executive Director of International Operations in the Criminal Investigation Division. He successfully designed and implemented novel strategies to detect and mitigate international financial crimes, devised an international financial crime strategy used to train and educate thousands of global investigators in over 50 countries. His most recent position was Executive Director of the Office of Fraud Enforcement. While in this position, International and Domestic fraud threat mitigation strategies were developed and implemented for all IRS business operating divisions. This office implemented a four-pillar intelligence model which aided in fraud detection. He led the COVID Relief Fraud Project and the Joint International Task Force.
Damon Rowe is currently an Adjunct Professor at Texas A&M University School of Law, where he teaches a course in international white-collar crime.
Mr. Rowe received his LL.M. in Tax from SMU Dedman School of Law and his J.D. from Texas Southern University Thurgood Marshall School of Law. He graduated from the University of Houston with a B.S. in Accounting.
Mr. Rowe was admitted to the Texas Bar in 1992.
Barbara T. Kaplan, Esq | Greenberg Traurig LLP
Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.
Lisa Perkins, Esq | Green & Sklarz LLC
Lisa Perkins joined Green & Sklarz after more than 17 years with the U.S. Department of Justice. She worked for five years as a trial attorney in the Western Criminal Enforcement Section of the Tax Division, prosecuting tax crimes in the western half of the United States, then moved to Connecticut. Until January 2015, she was an Assistant U.S. Attorney in Hartford, handling both civil and criminal litigation in federal court on behalf of the U.S. government. Her caseload included tax and financial crimes, immigration, employment discrimination, medical malpractice, Freedom of Information Act litigation and civil rights cases. Attorney Perkins is also an Assistant Clinical Professor and Associate Director of the Tax Clinic at UConn School of Law, where she supervises law students who represent low-income taxpayers before the IRS and in Tax Court.
Attorney Perkins has established a record of convincing government agents and attorneys to forgo criminal charges and civilly resolve many cases. In those cases where it was necessary for clients to either go to trial or plead guilty, Lisa has an exceptional track record of obtaining below guidelines sentences for clients.
Lisa is a Fellow of the American College of Tax Counsel, an organization in which membership is an honor reserved for those at the top of their chosen profession. The College’s members, called “Fellows,” are recognized for their extraordinary accomplishments and professional achievements and for their dedication to improving the practice of tax law. Fellows must be nominated by their peers for this honor. Self-nomination is not permitted. Each nominee must satisfy the established criteria and pass a rigorous screening process before he or she becomes a Fellow.
Attorney Perkins earned a bachelor’s degree from Michigan State University, a Juris Doctor from Michigan State University College of Law and an LL.M. in Taxation from Georgetown Law.
Walter Pagano, CPA, CFE | Eisner Advisory Group LLC
Walter Pagano is a Tax Partner with more than 35 years of diversified and relevant litigation consulting and forensic accounting experience. He has testified in federal and state courts, as well as at arbitration hearings, and has served as a federal, state, and bankruptcy court appointed forensic accountant and special fiscal agent. Walter’s experience, knowledge, and expertise enable practicing attorneys and corporate counsel to rely on his objective and independent critical thinking and judgment as a source to ascertain the financial facts in a wide variety of civil and criminal cases that have included white collar crime, internal investigations,
adequacy of internal controls, commercial disputes, civil and criminal tax controversy, internal and external fraud schemes, financial statement fraud, shareholder and matrimonial disputes, guardianship litigation, accounting malpractice and third-party asset misappropriation. Walter has served as an expert witness in diverse cases such as IRS practice and procedure, breach of accounting and tax representations and warranties, damage calculations, criminal tax prosecutions, and guardianship accounting.
Prior to joining the firm, Walter served as Partner-in-Charge of Litigation Consulting and Forensic Accounting at another public accounting firm. His background also includes serving 10 years as a revenue agent with the United States Treasury Department, Internal Revenue Service (IRS). In this position, Walter conducted forensic and tax audits of businesses and individuals, and also trained revenue agents and criminal investigation special agents in the applicable provisions of income tax law. In addition, he was an appeals officer, co-authored the IRS’ Commodity Tax Shelter Training Manual, examined abusive tax shelters, and assisted federal prosecutors as a forensic accountant in prosecuting various tax crimes.
Walter is a frequent guest speaker on topics such as forensic accounting, IRS investigations and white collar crime.
Michael A. Villa, Jr., Esq | Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
Mike was named a Texas Super Lawyer in Texas Monthly and Texas Super Lawyer Magazines in 2013-2022. In 2010-2013, he was named a Texas Rising Star. Mike focuses on resolving federal tax controversies and white collar crime, including securities, tax and bank fraud. He represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation, as well as in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, business torts, and other commercial disputes.
Prior to joining the firm in 2007, Mike worked in Washington, D.C. as a Congressional intern to U.S. Senator John Breaux (Retired) and worked as an Associate with a regional law firm in New Orleans, Louisiana. In 2004-2005, he served as a Judicial Clerk to the Honorable James J. Brady, U.S. District Court, Middle District of Louisiana.
Mike was admitted to practice in Texas in 2005 and in Louisiana in 2004.
Guinevere M. Moore, Esq | Moore Tax Law Group, LLC
Guinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies. She advocates for taxpayers at the IRS examination and appeals levels and, if a settlement with the IRS cannot be reached, in litigation. She is also the Executive Director of US Partnership Representative, Inc., and in that role she serves as a professional partnership representative.
Ms. Moore has represented taxpayers throughout her career, and draws on her experience in working with her clients, with the IRS, and with opposing counsel to help craft and execute the best possible plan to resolve the issues her clients are facing. Ms. Moore has successfully defended taxpayers against assessment of all types of federal tax, including income tax, employment tax, estate tax, gift tax, civil penalties, and criminal penalties.
Ms. Moore’s significant experience in practicing before the IRS and in the United States Tax Court enables her to work together with her clients to determine the best path forward to resolving the tax dispute – whatever Internal Revenue Code section may be at issue. The Internal Revenue Code contains thousands of provisions, and no tax professional has encountered them all. But having years of experience with the procedural hurdles that a taxpayer has to jump through in order to resolve a disagreement with the IRS over how much tax is due facilitates a much easier journey towards agreement or resolution through litigation.
Ms. Moore particularly enjoys the client counseling that she performs in her role as a taxpayer’s advocate. Having navigated hundreds of disputes with the IRS she is able to guide clients through what is often the most difficult crisis they are facing in their lives. Her clients will never wonder what comes next, or how the most recent development will impact them, because Ms. Moore routinely explains the process, the anticipated timeline, our strategy, and how all of the pieces come together. Ms. Moore will either partner with a client’s existing accountant, or, if necessary, engage a new accountant under a Kovel agreement.
Ms. Moore is actively involved in the American Bar Association, Section of Taxation. She is the immediate past Chair of the Standards of Practice Committee of the Section of Taxation. ABA Tax Times recently published an interview with Ms. Moore. Ms. Moore is also actively involved in the Accounting and Financial Women’s Alliance (AFWA), where she served as a member of the Board of Directors.
Ms. Moore draws on her many years of experience as a member of the Tax Bar to provide advice and insight to others. She is a co-author of Incompetent Authority, (a play on Competent Authority, the person legally designated authority to opine on matters of double taxation), a humorous advice column for tax lawyers published in ABA Tax Notes.
Ms. Moore is a frequent speaker at national and local conferences on topics related to tax, ethics, and the ethics of tax. Ms. Moore launched what has become an active pro bono program designed to help low income taxpayers receive representation that they could otherwise not afford. As part of this process, she co-authored and designed a four-part training series for representing low-income taxpayers before the IRS. She has been recognized for her pro bono work as the volunteer of the year by LadderUp, and has represented over one hundred clients pro bono.
Ms. Moore lives in Chicago with her husband and her four children. While she lives in Chicago, she represents taxpayers all across the United States and the world.
Hon. Victor Bolden
Judge Victor A. Bolden was sworn in as a United States District Judge on January 7, 2015. He received an A.B. degree from Columbia College in 1986 and a Juris Doctor from Harvard Law School in 1989.
After graduating from law school, Judge Bolden served as a Marvin Karpatkin Fellow for one-year and then as a staff attorney for more than four years with the American Civil Liberties Union Foundation’s National Legal Department. Thereafter, he became an assistant counsel with the NAACP Legal Defense and Educational Fund, Inc. from 1994 to 2000. From 2000 to 2005, he joined the law firm of Wiggin and Dana in New Haven, Connecticut, and served as an associate and later counsel. From 2005 to 2009, he returned to the NAACP Legal Defense and Educational Fund, Inc. to serve as its general counsel. In 2009, he was appointed the Corporation Counsel for the City of New Haven, Connecticut and served in that position until December 31, 2014.
Throughout his legal career, Judge Bolden has been active in national, state and local bar activities. He is a member of the American Bar Association’s Section of Litigation leadership and the New Haven Inn of Court and President-Elect of the New Haven County Bar Association. He previously served as a member of the board of directors for numerous organizations, including the Connecticut Veterans Legal Center and the Connecticut Food Bank.
Frank Agostino, Esq | Agostino & Associates
Frank Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, Mr. Agostino was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. He also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, Mr. Agostino taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. He also served as the co-director of the Rutgers Federal Tax Law Clinic.
Mr. Agostino is a frequent speaker and author on tax controversy and litigation matters. He serves on the Advisory Board of the Journal of Tax Practice and Procedure. Mr. Agostino is actively involved with the American Bar Association and the New York County Lawyers’ Association. Mr. Agostino is also the President of Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area.
Robert Day, Esq | Green & Sklarz LLC
Robert has more than a decade of experience counseling clients on state and local tax matters. His experience includes, but is not limited to, tax planning and optimization, compliance advice, domicile advice, and audit defense services for various tax types. Robert regularly provides clients with advice concerning state income, sales and use, and gross receipts taxes. Robert also has deals with less frequently encountered Connecticut taxes such as the controlling interest transfer tax and various taxes imposed on certain sectors such as petroleum and utilities.
Robert has worked with a broad range of clients such as individuals, tax exempt organizations and businesses ranging from new small businesses, family owned enterprises and Fortune 100 companies. His clients are in many industries and geographic areas. He has extensive experience with state tax issues unique to manufacturing, broadcasting, and financial services businesses, and he has assisted clients with financial statement reporting issues.
Robert is a member of the American Bar Association, the Connecticut Bar Association, and the Connecticut Society of Certified Public Accountants. Robert received a bachelor’s degree in business management from the University of Vermont and a juris doctor from the University of Connecticut. He is admitted to the bar in Connecticut and Massachusetts.
Anastasia King, Esq., Asst. United States Attorney | Department of Justice
Jeff M. Sklarz, Esq | Green & Sklarz LLC
Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs including: bankruptcy/bankruptcy litigation, creditor/debtor litigation, tax litigation, and commercial litigation. He regularly tries cases and appeals before Connecticut’s state and federal courts. Jeff has particular experience regarding the interplay between bankruptcy and tax law.
Jeff received his B.A. in government from Colby College, his J.D. from the University of Connecticut, School of Law, and his LL.M. (Taxation) from Boston University, Graduate Tax Program.
Jeff holds (and has held) many positions with local and national bar organizations and is a frequent writer and lecturer on topics involving bankruptcy, tax litigation and commercial litigation. Current positions include: Chair of the Bankruptcy Study and Reform Committee of the American Bar Association, Business Law Section, and Program Director for the American Bar Association, Business Law Section, Business Bankruptcy Committee. Jeff is also currently President of the New Haven Jewish Community Center.
Jeff is frequent lecturer and writer on topics involving bankruptcy and tax. He is also the co-founder of the New England IRS Representation Conference.
Chief James Lee | Internal Revenue Service
Jim brings a quarter-century of Criminal Investigation management and field experience into this key enforcement role.
Jim is highly respected throughout the IRS and will continue long-standing working relationships with the civil enforcement functions of the IRS as well as with the Department of Justice’s Tax Division and tax prosecutors throughout the country. He understands the need to support compliant taxpayers by maintaining a strong, robust enforcement effort focused on those who are compliance challenged.
Margaret Romaniello | Internal Revenue Service
Area Manager at Internal Revenue Service
Megan Brackney, Esq | Kostelanetz & Fink, LLP
Megan L. Brackney is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Ms. Brackney develops innovative strategies to resolve compliance concerns, voluntary disclosures, civil audits, and criminal investigations for individuals, trusts, estates, corporations, and partnerships, including audits conducted under the IRS’s centralized audit regime of the Bipartisan Budget Act. Ms. Brackney advocates for clients in IRS Appeals, and represents clients in litigation in the U.S. Tax Court and federal district courts. Ms. Brackney has successfully defended taxpayers against assessment of tax penalties, including income tax, trust fund recovery, and foreign information return penalties.
Daniel Mayo, Esq | Withum, Smith & Brown, PC
With over 20 years of professional tax experience in federal, international and financial products taxation, Dan helps businesses structure their affairs and plan transactions to minimize federal income taxes. He is experienced in mergers and acquisitions, capital markets transactions, and cross-border transactions, and he represents individuals and businesses in tax controversies with the IRS.
Dan is a recognized expert in the areas of qualified small business stock (QSBS) and the employee retention credit (ERC), and he co-leads Withum’s ERC Group. He keeps a pulse on federal income tax matters and upcoming legislation, and not only is he a thought leader within the Firm, but he is also an adjunct tax professor at Georgetown University Law Center and a frequent contributor to Forbes, writing on all things tax and sharing best practices for minimizing taxes for businesses and HNW individuals.
Michelle F. Schwerin, CPA, JD | Capes, Sokol, Goodman & Sarachan, PC
An attorney-CPA, Michelle’s credentials and experience allow her to navigate the intricate world of civil tax examinations, appeals, and litigation, as well as criminal tax investigations and defense. Michelle represents individuals and businesses in a variety of tax matters, including tax liability disputes, innocent spouse claims, claims for penalty abatement, refund claims and litigation, preparer and promoter penalty investigations and tax collection matters.
She also represents clients in all stages of federal and state securities investigations and litigation. She guides individual and business clients who come under investigation by the Securities Exchange Commission for issues such as public reporting, disclosures and insider trading.
Paul S. Hamann, President | RC Reports
Paul is an expert on determining Reasonable Compensation for closely-held business owners. He’s educated more than 100,000 financial professionals on the topic and has been published in numerous national and state journals. When he isn’t in the office, he enjoys spending time with his wife and chocolate lab, hiking Colorado’s back country or paddling its scenic lakes and rivers.
Sara G. Neill, Esq | Capes, Sokol, Goodman & Sarachan, PC
The Chair of Capes Sokol’s Tax Controversy and Litigation Practice Group, Sara Neill represents clients in civil and criminal tax disputes and litigation involving the Internal Revenue Service, Department of Justice and Missouri and Illinois Departments of Revenue. Sara was recognized as the St. Louis “Litigation and Controversy—Tax Lawyer of the Year” by Best Lawyers in both 2015 and 2018.
Sara handles federal and state tax audits and administrative appeals, as well as litigation before the U.S. Tax and District Courts. She frequently advises both individuals and businesses with sensitive tax problems, such as those who have failed to file returns, underreported their income, neglected to remit trust fund taxes to the Internal Revenue Service, pay significant amounts of tax due, or disclose foreign assets and accounts.
She also regularly represents clients in criminal tax investigations and litigation. Sara has defended several lawyers and accountants in IRS preparer/promoter investigations and appeals, as well as criminal tax cases. She frequently advises tax professionals with respect to matters involving Circular 230 and the IRS Office of Professional Responsibility, as well as in ethics and other disciplinary matters involving their professional licensing boards.
In addition to tax matters, Sara represents clients in other white-collar criminal matters involving allegations of financial fraud, including in the healthcare and securities areas.
John Heller, CPA, CFF | Marcum, LLP
John Heller is a Director in the Firm’s Advisory Services Division. He joined the Firm in 2008 from Barbee & Associates where he began his professional career in 1992. In January 2008 he joined Marcum’s predecessor, Rachlin Cohen & Holtz.
In addition to general business and tax accounting, Mr. Heller specializes in forensic accounting, litigation support and management duties for bankruptcy, insolvency, and litigation clients including numerous debtors, receivers, and panel trustees. His experience includes temporary business management of Chapter 11 properties and businesses; forensic review of books and records; identification and retrieval of concealed assets; analysis of preferential and fraudulent transfers; analysis of claims; solvency analyses; preparation of operating reports; forecasts for continued operations; liquidation analyses for Chapter 11 confirmation; preparation of Chapter 11 bankruptcy schedules and statement of financial affairs; and litigation support and testimony. Additionally, Mr. Heller provides transactional services and analyses related to mergers and acquisitions, due diligence and EB5 applications.
In addition to working with numerous U.S. trustees and state and federal receivers, Mr. Heller has conducted investigations in conjunction with the Securities and Exchange Commission, the Federal Trade Commission, the Federal Bureau of Investigation, the Commodity Futures Trading Commission and the U.S. Attorney’s Office.
Michelle Ferreira, Esq | Greenberg Traurig LLP
Michelle Ferreira is Co-Managing Shareholder of the San Francisco and Silicon Valley offices and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the California Department of Tax and Fee Administration , the Employment Development Department and county assessment appeals boards.
As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.
Michelle has 23 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.
Aaron Esman | Moore Tax Law Group, LLC
Aaron M. Esman, a tax controversy and litigation attorney, is an associate in the firm’s New York office. Mr. Esman represents individual and entity taxpayers in matters before the Internal Revenue Service, state & local taxing authorities, and the Department of Justice.
Mr. Esman has significant experience representing taxpayers in federal and state court cases, tax audits, and appeals proceedings. He has also advised clients on corporate transactions, mergers & acquisitions, state & local tax compliance, and prepared private letter ruling requests.
Mr. Esman is actively involved with the American Bar Association, Section of Taxation. He moderates a recurring panel at Section of Taxation meetings with staff members from the Internal Revenue Service.
Mr. Esman resides in New York and, in his spare time, can be found at one of New York’s many great theaters. He also gives back to his alma mater, serving on the University of Miami Alumni Council.
Kathy Enstrom | Moore Tax Law Group, LLC
Kathy Enstrom is the Director of Investigations for the Moore Tax Law Group and a former Executive within Internal Revenue Service Criminal Investigation (IRS CI). Having spent nearly 28 years in federal law enforcement, Ms. Enstrom has expertise in financial crimes, specifically income and employment tax evasion, money laundering, bank secrecy act violations, government assistance fraud and bank fraud.
Ms. Enstrom brings over a quarter of a century’s experience investigating financial crimes. She will assist clients facing governmental investigations and civil matters involving all manner of alleged tax, financial and economic fraud.
Ms. Enstrom began her IRS career in 1995 as an intern with IRS CI in Cedar Rapids, Iowa, and the year following was sworn in as a Special Agent in Chicago, Illinois. She then moved throughout the organization in various investigative and management roles. These supervisory roles were located in Chicago, New York City, Washington DC, Los Angeles, Milwaukee, Cincinnati, and Ottawa, Canada.
Ms. Enstrom rose to an executive position within IRS CI and her last assignment was to serve as Executive Director of Field Operations-Northern Area, overseeing one-third of the United States which included offices headquartered in Chicago, Detroit, Cincinnati, Philadelphia, Newark, Boston and New York City. Previous to this assignment, she was the Executive Special Agent in Charge for the Chicago Field Office and the Executive Director for CI’s Operations, Policy and Support. There she oversaw all CI policy and Internal Revenue Manual updates and the Financial Crimes Section, National Forensic Lab, Special Investigative Techniques Section, Warrants & Forfeitures Section, Treasury Liaison, TEOAF Liaison and FinCEN Liaison.
Ms. Enstrom’s time in federal law enforcement concluded with her role as Chicago’s Special Agent in Charge of Federal Deposit Insurance Corporation, Office of Inspector General from July 2021 to March 2023. In this role, she conducted investigations involving bank fraud and oversaw agents covering six states in the Midwest which included Illinois, Wisconsin, Indiana, Michigan, Ohio and Kentucky.
Ms. Enstrom has a Bachelor of Business Administration in Accounting from Mount Mercy University (Cedar Rapids, IA) and a Master of Business Administration from Cardinal Stritch University (Milwaukee, WI).
Ms. Enstrom lives in the northern suburbs of Chicago with her husband and a rescued Doberman Pincher, named Hank.
Karen Hawkins, Esq Attorney-at-Law | Yachats
After serving six years as the Director of the Office of Professional Responsibility for the Internal Revenue Service where she oversaw the standards of conduct for Attorneys, CPA’s, Enrolled Agents, Enrolled Retirement Plan agents, Actuaries, Appraisers and Unlicensed Return Preparers who “practice” before the Internal Revenue Service pursuant to Treasury Circular 230, She left government to reenter legal practice. Now after 5 years in the private sector as an educator, consultant and ethicist, she is hanging up my spurs and going happily (and mostly) into retirement. It’s been a great 41 years!
Zhanna A. Ziering, a tax controversy and litigation attorney, is a Member in the Firm’s New York office. Ms. Ziering’s practice focuses on representing individual and entity clients in civil and criminal tax disputes with federal and state governments as well as in regulatory proceedings. She defends both individual and entity taxpayers before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators.
Ms. Ziering advises taxpayers in connection with various tax issue, including those arising in connection with domestic and offshore income and assets, cryptocurrency, and U.S. tax and regulatory reporting requirements. She approaches each of her client engagements with empathy and kindness and develops a strategy for dispute resolution by taking the client’s views, needs, and resources into consideration. When faced with alternatives for dispute resolution, Ms. Ziering discusses the various available options, and the benefits and drawbacks of each such option, with the clients and works together with them to develop the approach tailored to that particular client and situation.
Ms. Ziering strives to resolve every tax dispute that her clients are facing amicably and efficiently while zealously advocating on her clients’ behalf. Her significant experience in representing clients in various stages of a tax dispute allows her to aptly navigate the procedural hurdles and achieve best results possible under the circumstances for each client.
A well-regarded member of the legal community, Ms. Ziering is actively engaged in American Bar Association, Section of Taxation. She currently serves as the Vice Chair of Court Practice and Procedure Committee. Ms. Ziering is also a sought-after speaker and writer on various topics relating to tax controversy and litigation. She is a co-author of the Bloomberg BNA’s Tax Management Portfolio, Report of Foreign Bank and Financial Accounts.
An avid supporter of the arts, Ms. Ziering had offered pro bono tax representation to artists from a diverse range of industries, such as film, music, and fashion. She also provided counsel to low-income taxpayers with a broad range of tax issues through Duke University School of Law’s Low-Income Taxpayer Clinic and New York University School of Law’s Tax Clinic.
Ms. Ziering lives in New Jersey with her husband, two rambunctious boys, and a Chocolate Labrador, named Mr. Chance Broadway. Ms. Ziering is a native Russian speaker and insists on reading all the great Russian literature in its original language.
Amalia Colbert, SB/SE Commissioner | Internal Revenue Service
As the SB/SE Commissioner, Lia Colbert oversees taxpayer programs and services affecting the nation’s small business and self-employed individuals. Lia provides oversight of SB/SE’s $2.34 billion budget and executive leadership to a staff of over 20,000 employees responsible for service and enforcement programs for 57 million taxpayers who file personal, corporate, flow-through, employment, and excise and estate and gift tax returns. She also has oversight for two Servicewide offices that focus on IRS civil efforts in detecting and deterring tax fraud, and analyzing and identifying abusive tax transactions, tax schemes and emerging abusive schemes.
Previously, Lia served as the Deputy Chief of the IRS Independent Office of Appeals where she worked closely with the Chief of Appeals in leading nationwide programs designed to enable Appeals employees to resolve tax controversies, without litigation, in a fair and impartial basis. Prior to that, Lia served in dual roles as the IRS Chief of Staff and the Taxpayer First Act (TFA) office executive lead. In her role as the IRS Chief of Staff, Lia worked closely with the IRS Commissioner and the senior leadership team to implement strategic priorities and initiatives critical to tax administration. As the TFA office executive lead, she oversaw Servicewide implementation of TFA provisions as well as delivering the TFA Report to Congress, bringing together a comprehensive taxpayer experience strategy, a holistic training strategy and a modernized IRS organizational structure.
Lia also previously held positions within the IRS Human Capital Office (including senior advisor to the HCO; Deputy Director, Employment, Talent and Security; and Director, Workforce Relations). Lia started her leadership journey in the Office of Appeals as a team manager, Collection Area Director and Appeals Training Director.
Hale E. Sheppard, Esq | Chamberlain, Hrdlicka, White, Williams & Aughtry
Hale Sheppard is a partner in the Tax Controversy & Litigation Section and Chair of the International Tax Section. He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues.
Patrick Deane, CPA | Aprio, Rockville
Amanda Evans, EA | Green & Sklarz LLC
Amanda is an enrolled agent (E.A) and paralegal with Green & Sklarz LLC. As an E.A., Amanda is a federally-authorized tax practitioner who has technical expertise in the field of taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all administrative levels—examination, collection, and appeals—of the Internal Revenue Service.
Amanda assists in both the tax representation and bankruptcy practice groups at the firm.
Amanda brings nearly 8 years of experience working for the Connecticut Bar Association (CBA) where she coordinated educational seminars for attorneys throughout Connecticut. She also managed the CBA’s attorney board certification program.
Amanda is the current Secretary of the Connecticut Society of Enrolled Agents and an associate member of the Connecticut Bar Association. She was a presenter at the 2016 New England IRS Representation Conference on issues surrounding representation of an innocent spouse and the 2017 New England IRS Representation Conference on IRS Offers-in-Compromise. In 2019, she presented at the New England IRS Representation Conference on Offers & Installment Agreements and focused her discussion on how to handle business assets. Amanda has also given presentations on hobby loss exams, IRS collection, tax liens and tax levies.
She is a 2006 graduate of Trinity College in Hartford and a current resident of Wolcott. In her spare time, she teaches group fitness classes at her local gym.
Caren Zhan, EA | Agostino & Associates, Hackensack
Tax professional with 31 years experience representing individual and business taxpayers in all administrative levels of the Internal Revenue Service (audits, collections, appeals) and before State and Local taxing authorities.
Agostino & Associates, PC is a boutique Tax Law Firm located in Hackensack, NJ 07601. Frank Agostino, Esq. has a national reputation for his expertise in all areas of Tax Controversy.
Beverly L. Winsted, Esq | Law Office of Beverly Winsted
Beverly Winstead, Esq., is an accomplished and award-winning tax attorney, law professor, Hall of Fame athlete and public speaker, bringing unmatched legal experience and a persistent focus on creating positive outcomes for her clients.
Ms. Winstead is known as much for her tax law expertise as she is for her passion for her clients. Whether she’s winning a high-profile client’s battle against the IRS or serving as the director of the Low-Income Tax Clinic at her alma mater, the University of Maryland School of Law, Ms. Winstead specializes in customized legal services for her clients’ personal and business needs.
From working as a budget analyst for Prince George’s County, Maryland, to teaching sports law as an adjunct professor, Attorney Winstead’s storied career in the wide-ranging field of tax law has propelled her to numerous legal victories for her clients both inside and outside of the courtroom.
Ms. Winstead has represented individuals, business owners and corporate officers. Some of her notable cases involved an IT company, that was audited by the IRS for several years which resulted in the company owing $1.2 million in taxes, penalties and interest. Prior to hiring us the company had worked unsuccessfully with two other representatives to resolve the case. Our team represented the company at the Appeals level. Using our audit experience we were able to get the $1.2 million assessment reduced to approximately $70,000. In another case, a client who was an officer of a corporation was personally assessed for withholding taxes that the corporation failed to pay. Our client was concerned that if he was held liable for the unpaid taxes that it would affect his credit, which in turn would cause him to lose his new job. We appealed the assessment and vigorously defended his position that he was not a responsible party. We were successful in getting the taxing agency to reverse its determination. Our client was not held liable for the unpaid taxes.
Sanessa Griffiths advises clients on a broad range of tax controversy matters and transactional situations.
Ms. Griffiths’ practice focuses on matters related to high-stakes and complex tax controversies involving transfer pricing, economic substance and business purpose doctrines, and tax treaty interpretation. With experience representing large U.S. and multinational companies at the audit, administrative proceeding and litigation phases, she routinely performs fact-finding and analysis in connection with multilayered tax matters, and assists clients in navigating legal and practical considerations of prelitigation and litigation work.
Ms. Griffiths is very active in Skadden’s diversity, equity and inclusion initiatives, particularly regarding the hiring and retention of attorneys of color. She is a member of the ABA steering committee that established the Loretta Collins Argrett Fellowship, which is focused on creating a more diverse, equitable and inclusive ABA Tax Section and tax bar. She also has been involved in several pro bono matters, including drafting amici briefs for the U.S. Supreme Court, advising on federal and state tax exemptions for nonprofit organizations and representing asylum seekers.
Eric L. Green | Green & Sklarz LLC
Attorney Eric L. Green is a practicing tax attorney, author, speaker, and coach. He founded Tax Rep LLC which runs the popular tax representation practice-growth training and coaching program Tax Rep Network. Through his role as the primary instructor and coach at Tax Rep Network, he has helped hundreds of accountants start and grow successful tax representation practices.
Eric is a partner and founder of law firm Green & Sklarz LLP, which is based in New Haven, Connecticut, where his focus is taxpayer representation before the IRS, Department of Justice Tax Division and state departments of revenue. Prior to becoming an attorney, Eric served as a senior tax consultant for national and international accounting firms, including KPMG and Deloitte & Touche.
Eric developed a national reputation by building a remarkable record of negotiating favorable settlements in thousands of civil cases against government agencies and has also been able to convince government agents and attorneys to forgo criminal charges and civilly resolve many cases.
Eric is a Fellow of the American College of Tax Counsel, an organization in which membership is an honor reserved for those at the top of their chosen profession. The College’s members, called “Fellows,” are recognized for their extraordinary accomplishments and professional achievements and for their dedication to improving the practice of tax law. Fellows must be nominated by their peers for this honor.
Eric is a frequent lecturer at American Bar Association Tax Section conferences, accounting conferences, and state Enrolled Agent conferences. He served as adjunct faculty at the University of Connecticut School of Law where he taught law students to handle taxpayer representation matters in the low income taxpayer clinic. He is often quoted in the Wall Street Journal, USA Today, CreditCard.com and Consumer Reports Financial News.
Eric is the author of the Accountant’s Guide to IRS Collection, the Accountant’s Guide to Resolving Tax Debts, a contributing author on Advocating for Low Income Taxpayers: A Clinical Studies Casebook and was interviewed for the book Stop Hiding from the IRS: The Insider’s Guide to Solving Your Tax Debts Once and For All.
Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honors graduate from New England School of Law. He earned a Masters of Laws in Taxation from Boston University School of Law.
DAY 1, Thursday, November 30, 2023
I. Knock-Knock: What to Do When Special Agents Are At Your Door – Moderator: Sara V. Spodick, Esq., Quinnipiac University Law School, North Haven, CT, Panelists: Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA, Damon Rowe, Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX, Barbara T. Kaplan, Esq., Greenberg Traurig LLP, New York, NY | 1:00pm – 2:00pm
Clients are often shocked to find out they are the target of a criminal investigation. Clients might know about it before agents show up, but often they don’t, and the knock at the door comes as a shock. The other surprise might be that other IRS Special agents are knocking at the tax preparer’s door at the same time! Our panel of experts will advise the audience what to do if there is a surprise knock at the door to protect themselves and avoid making a bad situation worse.
II.The Unfolding of a Criminal Tax Case – Moderator: Lisa Perkins, Esq., Green & Sklarz LLC, West Hartford, CT, Panelists: Walter Pagano, CPA, CFE, Eisner Advisory Group LLC, New York, NY, Michael A. Villa, Jr., Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX, Guinevere M. Moore, Esq., Moore Tax Law Group, LLC, Chicago, IL | 2:00pm – 3:00pm
Ever wonder what happens in a real criminal tax case? It is not like what you watched on late night television. These cases are fought over numbers in conference rooms with the use of criminal tax attorneys and forensic accountants. Our panel will describe what happens in these meetings, the role everyone plays and explain why most tax cases end in a plea.
Break | 3:00pm – 3:15pm
III.Day of Reckoning: The Federal Sentencing – Moderator / Introduction: Hon. Victor Bolden (invited), Defense Counsel: Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ, Taxpayer: Robert Day, Esq, Green & Sklarz LLC, New Haven, CT, United States Attorney: Anastasia King, Esq., Asst. United States Attorney, Department of Justice, New Haven, CT (invited) | 3:15pm – 4:00pm
The taxpayer has either plead guilty or been convicted at trial. For those who have never been involved with a criminal tax case, you are in for a real treat. We will take advantage of the beautiful Grand Courtroom at Quinnipiac and hold a mock sentencing so attendees can witness what actually happens in the court room at the end of a criminal tax case.
DAY 2, Friday, December 1, 2023
I. IRS Update – SB/SE Commissioner Amalia Colbert (invited) Interviewer: Jeff M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT, Criminal Investigation Chief James Lee (invited), Interviewer: Michael A. Villa, Jr., Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX, Stakeholder Liaison Margaret Romaniello (invited) Interviewer: Frank Agostino, Agostino & Associates, Hackensack, NJ | 8:30am – 10:00am
Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years of pandemic and the fallout afterward, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax and yet help struggling taxpayers. These panel interviews provide us with an update on new developments at the IRS.
Break | 10:00am – 10:15am
II. Enforcement Trends: What’s Hot and What’s Not – Moderator: Megan Brackney, Esq., Kostelanetz & Fink, LLP, New York, NY, Panelists: Daniel Mayo, Esq., Withum, Smith & Brown, PC, Red Bank, NJ, Michelle F. Schwerin, CPA, JD, Capes, Sokol, Goodman & Sarachan, PC, St. Louis, MO, Barbara T. Kaplan, Esq., Greenberg Traurig LLP, New York, NY | 10:15am – 11:05am
Following the Covid pandemic and the programs instituted by Congress we are about to enter a new era of tax enforcement, including Employee Retention Credits, Payroll Tax Debts, and much more. Join our panelists for a discussion of the changing tax enforcement landscape as it relates to examinations, collection and criminal investigations.
III.Wages vs Distribution: What is Reasonable Compensation? – Moderator: Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT, Panelists: Paul S. Hamann, President, RC Reports, Walter Pagano, CPA, CFE, Eisner Advisory Group LLC, New York, NY, Sara G. Neill, Esq., Capes, Sokol, Goodman & Sarachan, PC, St. Louis, MO | 11:05am – 12:00pm
Between 2010 and 2020 a parade of court cases, IRS Factsheets, and heightened IRS scrutiny and Preparer Penalties has brought the issue of “Reasonable Compensation for S Corps” out of the shadows and placed it forefront as a priority issue for tax professionals and clients. Our panel will debunk common myths and fiction on how reasonable compensation should be calculated and replace it with facts and methodologies that the IRS relies on, so that you can defend that number on the tax return you file on behalf of your client.
Lunch | 12:00pm – 12:45pm
IV.Hidden Assets and Fraudulent Transfers: What Accountants Need To Watch For! – Moderator: Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT, Panelists: John Heller, CPA, CFF, Marcum, LLP, Ft. Lauderdale, FL, Damon Rowe, Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX, G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA | 12:45pm – 1:45pm
Taxpayers wanting to avoid having their assets found by the IRS, former spouses or other creditors often try and hide those assets. Our panel will review what accountants and attorneys need to be on the watch for, what the consequences of attempting to hide those assets are and the potential fallout from it.
V.Ethical Practice & The Dangers of Getting Too Close to Clients – Moderator: Guinevere M. Moore, Esq. or Aaron Esman, Moore Tax Law Group, LLC, Chicago, IL, Panelists: Kathy Enstrom, Moore Tax Law Group, LLC, Chicago, IL, Karen Hawkins, Esq., Attorney-at-Law, Yachats, OR | 1:45pm – 2:45pm
Return preparers who get too close to their clients may slowly but surely blur the line between an independent preparer and someone who is actively working to achieve a specific result for the client. Loss of independence for a tax preparer can have disastrous results, both civil and criminal. This panel will discuss how to avoid losing independence and what the consequences can be when it happens.
Break | 2:45pm – 3:00pm
VI. IRS Enforcement Around Employee Retention Credits – Moderator: Zhanna A. Ziering, Esq., Moore Tax Law Group, New York, NY, Panelists: Amalia Colbert, SB/SE Commissioner, Internal Revenue Service, Washington, DC (invited), Hale E. Sheppard, Esq., Chamberlain, Hrdlicka, White, Williams & Aughtry, Atlanta, GA, Patrick Deane, CPA, Aprio, Rockville, MD | 3:00pm – 4:00pm
The Employee Retention Credits have been one of the most popular programs Congress created, and in many cases helped small businesses survive. However, being a refundable credit, the ERC also brought out the worst in some business owners, claiming credits they were not entitled to, and the IRS is ramping up its enforcement. Here from our panel what the status of enforcement is today, and what they are their clients need to know in case the IRS comes knocking about the ERC claims they filed.
VII. Appealing the Denied Offer – Moderator: Amanda Evans, EA, Green & Sklarz LLC, New Haven, CT, Panelists: Caren Zhan, EA, Agostino & Associates, Hackensack, NJ, Beverly L. Winsted, Esq., Law Office of Beverly Winsted, Laurel, MD, Sanessa S. Griffiths, Esq., Skadden, Arps, Slate, Meagher & Flom, LLP, Washington, DC | 4:00pm – 5:00pm
Perhaps you have seen this – the Offer you filed is being denied for what appears to be either bad analysis or seemingly weird analysis. It is not uncommon that the Offer-in-Compromise has to be taken to Appeals to be resolved. This panel will discuss how to dissect the analysis done by the IRS and what to address in your Appeal letter so you can get the case resolved favorably for your client.