ABA Section of Taxation

As the national representative of the legal profession, the mission of the ABA Section of Taxation is to serve its members and the public through education and leadership to achieve an equitable, efficient, and workable tax system.

	Event : ABATX1
- Sort By - Session Title Session ID Session : ABATX701A LOW INCOME TAXPAYER CLINIC WORKSHOP - REFUND CLAIM LITIGATION Filing Claims for Refund in US Tax Court, US District Court and the US Court of Federal Claims Conference : 2007 Midyear Meeting File Size : 7.4 MB Download Format(s) : MP3 $15.00 Prior to filing a claim for refund in the US Tax Court, US District Court and US Court of Claims, a taxpayer must exhaust his or her administrative remedies. This panel will discuss what steps a taxpayer must take within the IRS as a jurisdictional requirement to bringing suit before any court. Moderator: Paul Harrison, Community Tax Law Project Inc, Richmond, VA. Panelists: Elizabeth Davis, Trial Attorney, Department of Justice, Washington, DC; Professor Danshera Cords, Capital University Law School, Columbus, OH; Carol Nachman, Special Counsel (Procedure & Administration), Office of Chief Counsel, IRS, Washington, DC. “ABA Panel Notes: Session 1 - Filing Claims for Refund in U.S. Tax Court, U.S. District Court and the U.S. Court of Federal Claims,” by Elizabeth Lan Tax Workshop for New and Pro Bono Practitioners: Filing Claims for Refund “Disallowance of Earned Income Tax Credit,” IRS CCA 200202069; 2001 IRS CCA LEXIS 229 IRS Form 1040X (Rev. Nov. 2005), “Amended US Income Tax Return,” OMB No. 1545-0074 Mbiya B. Israel and Carrol Israel v. United States, US Court of Appeals for the Second Circuit, August Term, 2003 (Argued: November 19, 2003; Decided: January 22 , 2004), Docket No. 03-6112 “Refund Claims-- Jurisdictional Requirement to Bringing Suit Before Any Court and Time to Bring Such Suits: Focus on Original Returns Claiming an EITC,” by Leslie Book Session : ABATX701B LOW INCOME TAXPAYER CLINIC WORKSHOP - REFUND CLAIM LITIGATION Choice of Forum Conference : 2007 Midyear Meeting File Size : 14 MB Download Format(s) : MP3 $15.00 What forum your client should choose is as much a function of procedure as it is precedent within the forum. This panel will discuss the differences in discovery, pleadings, type of relief afforded, precedent, the litigating positions of Chief Counsel attorneys versus Department of Justice attorneys, and the role of judges in the settlement process in the US Tax Court, US District Court and US Court of Federal Claims. Moderator: Brian Trauman, Mayer Brown Rowe & Maw LLP, New York, NY. Panelists: Juan F. Vasquez, Chamberlain Hrdlicka White Williams & Martin, Houston, TX; Edward Froelich, Morrison & Foerster LLP, Washington DC; Professor Keith Blair, University of Baltimore School of Law, Baltimore, MD. “Panel Materials,” submitted by Brian P. Trauman “Hypothetical Situations,” submitted by Brian P. Trauman “Panel Biographies,” submitted by Brian P. Trauman Session : ABATX701C LOW INCOME TAXPAYER CLINIC WORKSHOP - REFUND CLAIM LITIGATION Claims for Damages Against the IRS Conference : 2007 Midyear Meeting File Size : 10.1 MB Download Format(s) : MP3 $15.00 This session will provide a guide to analyzing and pleading claims under IRC section 7433, Civil Damages for Certain Unauthorized Collection Actions, and IRC section 7430, award of attorneys’ fees. Moderator: Professor Steve Johnson, University of Nevada, Las Vegas School of Law, Las Vegas, NV. Panelist: Blaise Dusenberry, Special Counsel (Administrative Provisions & Judicial Practice), Office of Chief Counsel IRS, Washington, DC. Session : ABATX701D LOW INCOME TAXPAYER CLINIC WORKSHOP - REFUND CLAIM LITIGATION Trust Fund Penalties Conference : 2007 Midyear Meeting File Size : 11.5 MB Download Format(s) : MP3 $15.00 This session will provide a guide to litigating the imposition of trust fund recovery penalties, including trial strategies and discovery plans. Moderator/Panelist: Professor Jerry Borison, University of Denver School of Law, Denver, CO. Panelist: Elizabeth Davis, Trial Attorney, Department of Justice, Washington, DC. Session : ABATX701E LOW INCOME TAXPAYER CLINIC WORKSHOP - REFUND CLAIM LITIGATION Mock Trial of a Claim for Refund in US District Court Conference : 2007 Midyear Meeting File Size : 6.3 MB Download Format(s) : MP3 $15.00 This session will focus on litigating an Earned Income Tax Credit frozen refund claim. Panelists: Professor Keith Blair, University of Baltimore School of Law, Baltimore MD; Claudia Hill, Tax Mam Inc, Cupertino, CA. Mock Trial Testimony Session : ABATX702 SECTION BREAKFAST/PLENARY SESSION Susan P. Serota, Section Chair, Presiding Conference : 2007 Midyear Meeting File Size : 9.8 MB Download Format(s) : MP3 $15.00 Chair’s Report to the Section Susan P. Serota, Section Chair Adoption of Consent Calendar Bylaw Amendment Certificate Presentation 2006 - 2007 John S. Nolan Tax Law Fellows Announcement 2007 - 2008 John S. Nolan Tax Law Fellows Award Presentation 2007 Pro Bono Award Keynote Speaker MarkW. Everson, Commissioner, IRS, Washington, DC Recipient: Leslie M. Book, Director, Federal Tax Clinic, Villanova University School of Law, Villanova, PA. Session : ABATX703 ADMINISTRATIVE PRACTICE Chair: Thomas J. Callahan, Thompson Hine LLP, Cleveland, OH Conference : 2007 Midyear Meeting File Size : 29.3 MB Download Format(s) : MP3 $30.00 Important Developments. This panel will discuss important developments in administrative practice that have occurred since the 2006 Joint Fall CLE Meeting. Moderator: Jamie Hartford, Ernst & Young LLP, Washington, DC. Panelists: Rochelle Hodes, PricewaterhouseCoopers LLP, Washington, DC; Deborah A. Butler, Associate Chief Counsel (Procedure & Administration), IRS,Washington, DC. Impact of FIN 48 Disclosures on IRS Examinations and Administrative Practice. This panel will discuss the implications of the recent FASB disclosure rules concerning uncertain financial positions. Moderator: Sheri Dillon, McKee Nelson LLP, Washington, DC. Panelists: Robert D. Adams, Senior Advisor to the Commissioner (LMSB), IRS,Washington DC; Todd Simmens, Ernst & Young LLP, Washington, DC. National Taxpayer Advocate Review: Transparency of IRS. This panel will address IRS transparency questions such as: Are IRS personnel following procedures and guidance that practitioners don’t know about? Is the IRM that is available to the public different from the IRM that IRS personnel are using? Are some IRS personnel relying on legal analysis that is not available to the public? What is the IRS doing to improve its transparency? Moderator: Nina E. Olson, National Taxpayer Advocate, IRS, Washington, DC. Panelists: Eric R. LoPresti, Attorney Advisor to the National Taxpayer Advocate, IRS,Washington, DC; Susan B. Novotny, Director, Office of Servicewide Policy Directives & Electronic Research, IRS, Washington, DC; Christopher Bergin, Tax Analysts, Falls Church, VA. Session : ABATX704 AFFILIATED AND RELATED CORPORATIONS Chair: Victor Penico, Deloitte Tax LLP, San Francisco, CA Conference : 2007 Midyear Meeting File Size : 27.8 MB Download Format(s) : MP3 $30.00 Loss Disallowance and Loss Duplication Regulations. Eagerly awaited regulations revising the current loss disallowance and loss duplication schemes are expected to be proposed before the meeting. This panel will provide a comprehensive overview of the regulation package. (If the regulations are not filed by the time of the meeting, an alternative program will be presented.) Moderator: Victor Penico, Deloitte Tax LLP, San Francisco, CA. Panelists: Andrew Dubroff, Ernst & Young LLP, Washington, DC; Jonathan Forrest, Deloitte Tax LLP, Washington, DC; Theresa Abell, Special Counsel to the Associate Chief Counsel (Corporate), IRS,Washington, DC; Marc Countryman, Attorney Advisor, Office of Tax Legislative Counsel, Department of Treasury,Washington, DC. Current Developments. This panel will discuss recent consolidated return developments. Moderator: Derek Cain, PricewaterhouseCoopers LLP, Washington, DC. Panelists: Mark Schneider, Deputy Associate Chief Counsel (Corporate), IRS, Washington, DC. Session : ABATX705 BANKING AND SAVINGS INSTITUTIONS Chair: John Ensminger, Law Offices of John Ensminger, New York, NY Conference : 2007 Midyear Meeting File Size : 27.7 MB Download Format(s) : MP3 $30.00 Industry Overview and Audit/Litigation Issues. This session will provide an overview of the financial institutions industry and, in particular, will discuss recent tax controversy developments affecting the industry. Moderator: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA. Panelist: Barry Shott, Industry Director, Financial Services, IRS, Washington, DC. Recent Regulatory Developments. This panel will discuss regulatory and other Department of Treasury and IRS pronouncements, and significant case law developments preceding the session. Moderator: Hayden Brown, Mayer Brown Rowe & Maw LLP, Charlotte, NC. Panelists: Bethany Ingwalson, Attorney-Advisor, Office of the Associate Chief Counsel, IRS, Washington, DC; Michael Novey, Associate Tax Legislative Counsel, Department of Treasury, Washington, DC. FASB Developments. This session will discuss the final guidance issued by FASB on Accounting for Income Taxes (FIN 48) and Accounting for Leases (FAS 13), with an emphasis on the implications to financial institutions. Moderator: KennethW. Busey, PricewaterhouseCoopers LLP, Washington, DC. Panelist: Charles M.Wheeler, Alston & Bird LLP, Washington, DC. Session : ABATX706 CLOSELY HELD BUSINESSES AND STATE & LOCAL TAXES Chair: John O. Tannenbaum, Law Offices of John O. Tannenbaum, Hartford, CT Conference : 2007 Midyear Meeting File Size : 28 MB Download Format(s) : MP3 $30.00 Nexus - The Power of States to Tax Out of State Businesses and Nonresident Business Owners. This panel will discuss when an expanding closely held business and its owners will become subject to tax in additional states. Moderator: Rick Handel, Senior Administrator and General Counsel for Policy, South Carolina Department of Revenue, Columbia, SC. Panelists: C. Eric Fader, Horwood Marcus & Berk Chartered, Chicago, IL; Shirley K. Sicilian, General Counsel, Multistate Tax Commission, Washington, DC. Sourcing and Apportionment of Tax Items Related to Pass Through Entities. This panel will discuss how states treat flow through entities and their owners. This discussion will focus on when and how income, credits and apportionment factors pass through the entities to their owners. In addition, the panel will analyze the impact of unitary relationships on the apportionment or allocation of flow through entity income. Moderator: Jordan M. Goodman, Horwood Marcus & Berk Chartered, Chicago, IL. Panelists: Michael T. Donovan, Baker & McKenzie LLP, Chicago, IL; Bruce Ely, Bradley Arant Rose & White LLP, Birmingham AL. Other State Tax Issues Affecting Expansion into Other States. This panel will explore other state tax issues involved in structuring a business expanding to multistate operations, including transfer tax aspects of entity formations, reorganizations, and dissolutions. Moderator: Robert Joe Hull, Bracewell & Giuliani LLP, Houston, TX. Panelists: John R. Shaughnessy Jr, Robinson & Cole LLP, Hartford, CT; StewartWeintraub, Schnader Harrison Segal & Lewis LLP, Philadelphia, PA.

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