On-Demand: November 7 – November 8, 2024
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The New England IRS Representation Conference brings together representatives from the government and expert private practitioners to compare perspectives on a broad range of topics involving federal tax audits, appeals, and litigation. Coverage encompasses the entire scope of representation work, from anticipating and planning for the examination of a return through resolution of all un-agreed issues. Enforcement is an essential part of our federal tax system. The New England IRS Representation Conference is an opportunity to stay current as well as to exchange ideas and share practice tips, which can contribute to better functioning of the system. The conference is designed for tax professionals at all levels who prepare for or handle audits, appeals or tax litigation, as well as those involved in planning and transactional work who could benefit from a better understanding of the implications of their work for audit defense.
This course is co-sponsored with myLawCLE.
Closed-captioning available
Eric L. Green | Green & Sklarz, LLC.
Eric is a managing partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services. He is a frequent lecturer on tax topics for many national organizations, including Insightful Accountant, CCH, the NAEA, the NATP, the ABA Tax Section and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He was the author and lecturer of the University of Connecticut School of Business IRS Representation Certificate Program, and has served as a columnist for CCH’s Journal of Practice & Procedure. He is the founder of Tax Rep LLC which coaches accountants and attorneys on building their own IRS Representation practices, and is the host of the weekly Tax Rep Network Podcast.
Mr. Green is the author of The Accountant’s Guide to IRS Collection, The Accountant’s Guide to Resolving Tax Debts, The Accountant’s Guide to Resolving Payroll Tax Debts and The Insider’s Guide to Offers-in-Compromise.
Walter Pagano, CPA, CFE, CFF | EisnerAmper
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.
Kathy Enstrom | The Moore Tax Law Firm
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 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). She is also a Certified Fraud Examiner through the Association of Certified Fraud Examiners and an Enrolled Agent and authorized to represent taxpayers before the Internal Revenue Service.
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 lives in the northern suburbs of Chicago with her husband and a rescued Doberman Pincher, named Hank.
Craig Cafaro, CPA, CFF | Citrin Cooperman Advisors LLC
With over 25 years of experience, Craig Cafaro is a partner focused on tax planning and compliance for high net worth individuals, entities and trusts in a wide variety of industries including family office, real estate, and franchise. In addition, Craig specializes in providing litigation support and forensic accounting services to clients in the areas of tax controversies and criminal and civil investigations.
Craig has extensive experience advising clients in connection with the IRS Offshore Voluntary Disclosure Program, as well as various state programs. He also successfully represents clients before the Internal Revenue Service and various state taxing authorities regarding tax examinations, penalty abatements, the Offer in Compromise program, and other tax complexities. He is a member of the firm’s Offshore Voluntary Disclosure Initiative Committee and Tax Quality Control Committee.
Prior to joining Citrin Cooperman, Craig was a partner at Leon M. Reimer & Co., P.C., and also served as an internal auditor in the banking and insurance industries
Amalia Colbert | Internal Revenue Service
Commissioner, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC.
Guy Ficco | Internal Revenue Service
Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC
Elizabeth P. Askey | Internal Revenue Service
Liz Askey is Acting 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.
Liz rejoined the government in 2019 as Deputy Division Counsel (International) for the Large Business and International Division at the IRS. Prior to that she spent nearly 30 years assisting clients with both preventing and resolving complex tax controversies. She represented clients before the IRS Examination and Appeals Divisions, in litigation, in ruling requests before the IRS, and in policy matters (both regulatory and legislative), before the US Department of the Treasury and the Congressional tax-writing committees.
Liz is a former Associate Tax Legislative Counsel in the Treasury Department’s Office of Tax Policy and also has Big Four, law firm, and in-house experience
Jeffrey 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.
Jeffrey M. Sklarz was named the Best Lawyers® 2022 Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law “Lawyer of the Year” in New Haven and was included in the 2021 Edition of The Best Lawyers in America© for Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law. He is a Fellow of the American College of Tax Counsel (ACTC). Jeff is a 2005 recipient of the Connecticut Law Tribune’s New Leaders of the Law Award (Overall Achievement, Fairfield County) and has been listed by New England Super Lawyer® as a Super Lawyer (Business Litigation) since 2010 (Rising Star 2010-2013) and was named a Fellow of the American Bar Association, Business Law Section (2011 – 2013).
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.
Jeff regularly serves as counsel to clients experiencing a wide of array of financial challenges, typically involving some form of “bet the company” matters.
G. Michelle Ferreira | Greenberg Traurig LLP
Michelle Ferreira is Senior Vice President, Co-Chair of the Global Tax Practice, and Co-Managing Shareholder of the San Francisco and Silicon Valley offices. She 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 split dollar life insurance, 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.
James R. Grimaldi | Citrin Cooperman Advisors LLC
James Grimaldi, a tax partner, has more than 30 years of experience providing strategic tax planning, research, and compliance services. His clients include business owners in a range of industries, including real estate, manufacturing, and family offices, as well as not-for-profits and high net worth individuals. As a tax attorney, he also advises clients on trust and estate planning. Prior to joining Citrin Cooperman, Jim was a tax partner at two regional firms. He began his career in the tax department of a Big Eight firm.
As a specialist in tax controversy, Jim represents clients before the IRS Appeals Office, the U.S. Tax Courts, and state and local taxing authorities on personal, business, and fiduciary income tax matters. He has successfully navigated the private letter ruling filing process, and as a result, was able to save millions of dollars in tax. Jim also has deep expertise in state residency audits, helping clients to minimize tax exposures and penalties. In addition, Jim is highly knowledgeable in federal and state tax credits. In the state tax area, he advises clients on various state and local tax issues, including state tax nexus. As a business consultant, Jim helps S corporations, limited liability companies, and flow-through entities with tax planning and projections throughout the year. He works with closely held, family-owned businesses and commonly controlled businesses. For clients in the manufacturing industry, he advises on business purchases and sales.
As a member of the firm’s Trust and Estate Practice and chair of its Education Committee, Jim helps individuals and families preserve and grow their wealth through a variety of tax-efficient strategies. He is regularly involved with probating wills and assisting trustees, executors, and administrators in overseeing estates and trusts. He has also served as an executor and trustee.
Jim is a member of the firm’s Not-for Profit Committee and Tax Quality Control Committee.
Christopher M. Ferguson, Esq. | Kostelanetz
Mr. Ferguson represents clients in both federal and state courts, as well as before governmental agencies and other regulatory bodies, including the U.S. Department of Justice, the Internal Revenue Service, the Securities and Exchange Commission, FINRA, the New York Attorney General’s Office, the U.S. Department of Labor, the New York City Department of Investigations and the Manhattan District Attorney’s Office. He has defended clients in federal and state investigations and prosecutions involving allegations of tax fraud, securities fraud, anti-trust violations (bid rigging and price fixing), Bank Secrecy Act violations, mail and wire fraud, CARES Act fraud, prevailing wage fraud, theft of government services, fraud related to state and local Minority and Women Business Enterprise (“MWBE”) programs, and other violations of federal and state law.
In his civil practice, Mr. Ferguson has represented both plaintiffs and defendants in a variety of complex commercial matters, including wage and hour class actions, tax shelter litigations, government procurement matters and commercial litigations involving breach of contract, breach of fiduciary duty, fraudulent conveyances, civil fraud, civil RICO, civil forfeiture and similar claims.
Mr. Ferguson also conducts internal investigations for institutional clients whose officers and/or employees have been suspected or accused of wrongdoing.
Mr. Ferguson received his B.A., magna cum laude, from Boston College and his J.D. from New York University School of Law. Prior to joining Kostelanetz LLP, he served as a law clerk to the Honorable Jay C. Waldman of the United States District Court for the Eastern District of Pennsylvania, and was associated with the law firm of Dewey Ballantine, LLP, where he practiced in the areas of complex commercial, antitrust, and bankruptcy litigation.
Mr. Ferguson is recognized in Super Lawyers and is a member of the New York Council of Criminal Defense Lawyers. He is also the former Secretary of the Criminal Law Committee of the Bar Association of the City of New York and has published and spoken extensively in the areas of white collar criminal and civil and criminal tax controversies.
Miri Forster, Esq. | Eisner Advisory Group
Miri Forster is a Partner and National Leader of the Tax Controversy & Dispute Resolution practice group, specializing in providing tax dispute resolution services to public and private corporations, partnerships and high net worth individuals on a wide range of technical and procedural issues. She has over 20 years of IRS practice, procedure, and tax controversy experience.
Miri represents businesses and individuals before the IRS Examination and Appeals Divisions on complex domestic and international tax issues. She also obtains private letter rulings from the IRS National Office, including 9100 relief requests for missed elections. Miri assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors, obtains penalty abatements and refunds, resolves IRS account issues, and advises on a broad range of IRS practice, procedure and dispute resolution matters.
Prior to joining the firm, Miri was a Tax Controversy Principal at a Big 4 firm. Miri also previously served as an Attorney-Advisor at the United States Tax Court in Washington, D.C., and is an attorney licensed in the states of New York and New Jersey as well as Washington, D.C.
Miri is a frequent speaker on IRS enforcement trends, the centralized partnership audit regime and its impact on pass-through entities and investors, voluntary disclosures of inadvertent tax compliance matters and related penalties, and other IRS practice, procedure and dispute resolution topics.
Miri was named a 2022 honoree of the Executive Women of New Jersey’s Policy Makers. She also serves as Co-chair of Women of EisnerAmper, New Jersey Chapter.
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.
Carolyn Schenck | Internal Revenue Service
National Fraud Counsel and Assistant Division Counsel (International), IRS Office of Chief Counsel, Washington, DC.
Damon Rowe, Esq., CPA | Meadows Collier Cousins Crouch Reed & Ungerman LLP
Damon Rowe joins Meadows Collier after two decades of service at the IRS. His practice focus is White-Collar Crime and Government Regulatory Litigation, Tax Controversy and Litigation, and Cryptocurrency and Digital Assets. 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 served on the law faculty as an Adjunct Professor at Texas A&M University School of Law, where he taught 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.
Eli Knoff, Esq., CPA | Frost Law
Eli utilizes his background as a CPA and attorney to vigorously defend clients before the IRS and state taxing authorities. He currently serves as co-Chair of the Tax Controversy Department. Eli is also the firm’s lead on international tax matters, which involves complex international tax compliance issues, resolving many offshore voluntary disclosures and streamlined filing compliance procedures, as well as preparing complex Passive Foreign Investment Company (PFIC) computations. He also represents clients in a significant number of tax collection matters, federal and state examinations and appeals, IRS criminal investigations, and matters before the federal and state tax courts.
Eli has been a part of Frost Law since it began. His tireless efforts in all aspects of the firm’s practice have been instrumental in fueling the firm’s success and growth.
Eli was a Legal Extern at the Internal Revenue Service Office of Chief Counsel, where he conducted legal research, analyzed cases for potential strengths and weaknesses, participated in settlement conferences, drafted proposed factual stipulations to comply with court rules, and drafted several pleadings and motions.
Eli also managed a team of accountants at the Baltimore Creating Assets Savings and Hope Campaign, a non-profit tax preparation organization, where he prepared income tax returns for moderate-income families, provided tax expertise to tax preparers, ensured quality review, and maintained the site in accordance with IRS regulations. Under Eli’s supervision, his team was awarded the Quality Tax Preparer Award for the lowest number of organization-wide rejected returns.
Eli is a graduate of the University of Maryland School of Law where he received his Juris Doctor with honors. Eli is an active member of the American Bar Association and the Maryland State Bar Association. He is admitted to practice law in the State of Maryland and is a licensed Maryland CPA. He has also been recognized by Super Lawyers as a Rising Star.
Eli is a husband and father of five and enjoys traveling and spending time with his family. His ultimate goal at Frost Law is to utilize his analytical skills to quickly and proficiently identify problems within tax cases and solve problems favorably for his clients.
Darren Guillot | alliantGroup
As an alliantgroup trusted tax advisor and consultant, Mr. Guillot assists small and medium-sized businesses navigate America’s tax system to secure incentives and credits that stimulate innovation and improve products and services. He also serves them as an expert resource resolving complex compliance and appellate controversies.
Mr. Guillot recently retired from IRS after 36 years with the agency. His roles included serving as Commissioner of the IRS’ Small Business/Self Employed Division, overseeing all IRS domestic and international Collection Operations and its Operations Support functions. In his role as Commissioner, SBSE (2021 – 2022) he led IRS’ groundbreaking, successful effort using authenticated voice robotics, eliminating phone hold times for over 14 million taxpayers in less than two years. He also led the creation and oversight of IRS’ Fraud Enforcement Office, providing support and coordination for all IRS efforts in detecting and deterring tax fraud – including leading the most expansive and innovative use of data and systems analytics to address virtual currency by the civil functions of the IRS.
Darren’s extensive enforcement background at IRS was balanced by his 14 years’ experience in IRS’ Independent Office of Appeals, culminating in his creation, implementation, and top leadership of the Appeals Judicial Approach & Culture Project (2011 -2013) and its resulting policies and procedures in use to this day. He began his IRS career as a revenue officer and holds a bachelor’s degree from the University of Holy Cross, is a fellow of the Loyola University Institute of Politics and was awarded the Certificate in Public Leadership by the Brookings Institution.
Beverly Winstead, Esq. | Law Office of Beverly Winstead
Beverly Winstead, J.D., is a national speaker, podcaster, professor, author and principal of the law firm, Law Office of Beverly Winstead, LLC. Beverly is a personal and small business tax and legal expert who helps clients get out of tax debt and then build back and protect their wealth through wealth management strategies.
She teaches tax law at the University of Maryland, Carey School of Law, and has helped hundreds of students navigate the complexities of taxes. Taxes can be daunting for so many people but Beverly has found her calling by breaking down the tax system and sharing simple strategies that can help anyone navigate resolving a tax matter.
In her first book, Get out of Tax Debt Now, The Taxpayer Playbook to Dealing with the IRS, Beverly, a former college basketball player, uses the life skills she learned on the basketball court as a guide to helping anyone resolve their tax problems. During her tenure at Bowie State University (BSU), she won 3 conference championships. In 2014, she was inducted into the BSU Sports Hall of Fame.
Beverly can be heard weekly on a podcast: The Three Money Amigos, where she discusses a wide array of tax, legal and investment matters. In addition to her podcast, she pours a significant amount of time teaching financial literacy and entrepreneurial skills to youth. She hosts an annual financial fitness workshop for youth in underserved communities.
Amanda Evans | 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.
David Shuster Esq. | Marcum, LLP
David Shuster, a Marcum Tax & Business Services partner, advises, represents, and defences clients before the IRS and state tax authorities. Dave also consults with corporations, partnerships, private foundations, public charities, and individuals on federal and state tax planning and compliance matters.
Beginning his career at the United States Department of Justice, Dave was appellate counsel to the federal government in a wide variety of tax cases. There, he briefed and orally argued cases in nearly all of the federal circuit courts of appeals. He also advised and assisted the Solicitor General’s Office in its Supreme Court litigation. Subsequently, as a tax partner at an international law firm, Dave focused on tax controversy, planning, and compliance issues.
Eric Hylton | alliantGroup
Former IRS Commissioner of the Small Business/Self Employed Division; alliantgroup National Director of Compliance.
Hylton held several prominent positions at the IRS, including serving as Deputy of the Criminal Investigation Division and as CI’s head of International Operations.
As National Director, Eric employs his years of experience at the IRS to assist alliantgroup’s clients as an ambassador for U.S. small and medium sized businesses (SMBs) and in helping others become tax compliant
Daniel Mayo, Esq. | WithumSmith+Brown, PC, Red Bank
Daniel has more than 20 years of professional tax experience as well as experience in federal, international and financial products taxation. He is experienced in mergers and acquisitions, capital markets transactions, and cross-border transactions. He is also a recognized expert in the employee retention credit and frequently represents clients in tax controversy matters before the IRS.
Daniel is a frequent author and speaker on U.S. Federal income tax topics. He is an adjunct faculty member with Georgetown University Law Center and an approved arbitrator for FINRA. Daniel is a member of the New York and New Jersey Bars, the American Bar Association, previously the chair of the Banking & Savings Institutions Tax Committee, and the New York Bar Association.
Frank Agostino, Esq. | Agostino & Associates, PC.
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 | 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.
Michael D’Addio, Esq. | Marcum LLP
Michael F. D’Addio is a principal in the Firm’s New Haven, Connecticut, office. He has more than 40 years of experience as a specialist in compliance and planning in a variety of areas concerning federal and state taxation. His industry experience includes construction, real estate, research and development, professional services, and manufacturing. He has extensive experience in planning business transactions, including mergers and acquisitions, business entity formations and dissolutions, and sales transactions.
Michael has developed a number of planning strategies for clients in the areas of estate and gift planning. These include the use of trusts for tax savings and asset protection.
He regularly reviews legal documents and assists other professionals in their drafting to ensure that they accomplish clients’ overall tax and economic objectives and to determine that they comply with the relevant tax authority. Based upon his clients’ unique facts, circumstances, and goals, he has devised individualized strategies designed to minimize their tax liabilities while retaining assets and income. His plans combine highly technical tax rules with the business and personal needs of clients.
Michael has represented clients before the Internal Revenue Service and other state and regulatory agencies. He has vigorously advocated client positions before various administrative levels of these taxing authorities and assisted their legal advisors in court proceedings. In addition, he has handled a variety of collection matters, including negotiation of deferred payment arrangements and Offers in Compromises. He has been involved in the preparation of government letter rulings and technical advice memoranda covering a range of tax issues.
Michael is a sought-after lecturer on a range of federal and state tax issues before client and business groups. He has been a main speaker in technical sessions for many professional organizations. In addition, he has instructed courses in the Master of Taxation program at the University of New Haven. He also conducts tax training sessions for the professional staff of the Firm.
Paul Hamann | RCReports
As the Founder and President of RCReports, I have more than 13 years of experience in providing online solutions for determining Reasonable Compensation for Closely-Held Business owners. My mission is to help Tax and Financial advisors confidently and accurately assess the fair market value of their clients’ wages, based on a proprietary blend of IRS criteria, court rulings, geographic data, and our exclusive database of wages.
I have also taught over 100,000 CPE hours on the topic of Reasonable Compensation for S Corp owners through NASBA certified courses, and authored multiple publications on the subject. My software has helped thousands of advisors and business owners successfully defend their Reasonable Compensation figures against IRS challenges, saving them time, money, and stress. I am passionate about simplifying and streamlining the process of determining Reasonable Compensation, and empowering Small Business advisors with the tools and knowledge they need to serve their clients effectively.
Barbara T. Kaplan | Greenberg Traurig LLP
Barbara T. Kaplan, Chair of the New York Tax Practice, 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.
DAY 1, THURSDAY, NOVEMBER 7, 2024
How to Utilize IRS E-Services | 2:00pm – 2:50pm
Join us for this special panel where we hear from the experts, including directly from the IRS, about all the thorny issues you have wrestled with when it comes to e-services, including ID Me, Tax Pro Accounts, and transcript delivery. They will also review the new portals and use of uploads to provide documents to the IRS.
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Break | 2:50pm – 3:00pm
Data Security and The Fallout From a Data Breach: What Every Tax Pro Needs to Know | 3:00pm – 4:00pm
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The Role of the Forensic Accountant | 4:00pm – 5:00pm
Forensic accountants use specialized techniques to uncover and explain financial and accounting anomalies and improper conduct. They are retained as consultants and testifying experts in a broad range of civil and criminal tax cases, serving as essential components of a legal team’s resolution strategy. This panel explores the role of the forensic accountant and how they can best work with tax practitioners in defending their client in a tax controversy.
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DAY 2, FRIDAY, NOVEMBER 8, 2024
IRS Update | 8:35am – 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
Enforcement Trends: What’s Hot and What’s Not | 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, Crypto Currency, 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.
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Out of the Frying Pan and Into the Fire: What Makes a Case Move from the Civil Function to IRS Criminal Investigation | 11:05am – 12:00pm
So, the client and their tax professional might have become a bit overzealous in their planning and now the IRS is looking at the positions taken on the return. What makes a case move from the civil side of the IRS to Criminal Investigation? Our panel of current and former criminal tax experts will walk you through the government review and weighing of the factors it goes through in making that determination.
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Lunch | 12:00pm – 12:45pm
Creative Collection Alternatives | 12:45pm – 1:45pm
Issuance of collection notices have resumed in full force and the IRS has increased its efforts to pursue high net worth taxpayers with outstanding tax debt. One of the most common questions raised by taxpayers faced with potential or assessed tax liabilities is: What are my options? A simple question that requires the tax professional to explain the numerous and often complex paths to resolving federal liabilities. While navigating the numerous options, taxpayers must address ever-increasing enforcement actions, including, but not limited to, the filing of Notices of Federal Tax Lien, levies and wage garnishments, responsible person investigations, and nominee or alter ego liens. This panel reviews a taxpayer’s options, best practices, and tips of the trade.
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How to File a Refund Claim | 1:45pm – 2:45pm
Maybe it is a mistake on a prior return, the taxpayer needs to challenge a bad tax assessment, or a preparer who disagrees with preparer penalties assessed against them by the IRS. In all of these cases, paying some or all of the assessment and filing a refund claim is a legitimate way to reopen and have these issues looked at. This panel will review the procedures for filing a refund claim, under what circumstances the entire tax must be paid versus just a percentage, and what the process looks like for challenging the IRS decision in court.
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Break | 2:45pm – 3:00pm
ETHICS: Handling Employee Retention Credit Audits and Investigations: Coloring in the Lines | 3:00pm – 4:00pm
Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. To address questionable claims, the IRS recently announced a Voluntary Withdrawal and Voluntary Disclosure Program to give taxpayers with possibly ineligible claims an opportunity to come forward, cooperate with the IRS, and, in return, minimize their financial exposure including penalties. The IRS is also aggressively auditing ERC claims and pursuing penalties and criminal prosecutions for ERC related abusive schemes and fraud. This panel of experienced practitioners discusses the IRS’s targeted enforcement efforts, explains how to spot red flags indicating abuse of the ERC, describes the penalties that apply to taxpayers, promoters, and practitioners for erroneously claiming ERC credits, and addresses the filing of the corresponding wage reduction on an income tax return.
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Net Worth Taxpayer Audits: The Tax Man Cometh | 4:00pm – 5:00pm
This panel will review the hot button topics when comes to IRS examinations of high net worth individuals and their businesses. The panel will include hot button topics with S Corporations and Partnership returns, high income non-filers, reasonable compensation and basis issues.
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