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Caroline D. Ciraolo Participated on the Panel "Application of Authority in the Changing World of Deference" at the 67th Annual Taxation Conference held at the University of Texas School of Law in Austin, TX

Caroline D. Ciraolo participated on the panel "Application of Authority in the Changing World of Deference" at the 67th Annual Taxation Conference held at the University of Texas School of Law in Austin, TX on December 5, 2019. 

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Megan Brackney presented a CLE program entitled “Walking Through the Various States of the Partnership Audit Rule Process" on December 4, 2019

Megan Brackney presented at the American Law Institute course entitled “Representing Partnerships in Tax Audits, Controversies, and Litigation with the IRS,” on December 4, 2019.

The new partnership audit rules represent the most substantial change to audits in almost four decades. For partnerships, including LLCs taxed as partnerships, the opening of audits at this time and into the future will be governed by the new regime. In application, the new audit rules can significantly change audits and litigations, including who is responsible for tax payments and how deficiencies are attributed to partnerships, equating to a monumental tax procedure paradigm shift. Many practitioners possess a general understanding of these changes, but few possess an in-depth understanding of the impact these new rules will have. This program got down to the brass tacks of what the new audit rules look like in action - at formation, during the audit process, and on appeal, so that you can make more out of your pre-game planning!

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Megan Brackney presented a CLE program entitled “Challenges in Representing the Partnership and Partnership Representative” on December 4, 2019

Megan Brackney presented at the American Law Institute course entitled “Representing Partnerships in Tax Audits, Controversies, and Litigation with the IRS,” on December 4, 2019.

The new partnership audit rules represent the most substantial change to audits in almost four decades. For partnerships, including LLCs taxed as partnerships, the opening of audits at this time and into the future will be governed by the new regime. In application, the new audit rules can significantly change audits and litigations, including who is responsible for tax payments and how deficiencies are attributed to partnerships, equating to a monumental tax procedure paradigm shift. Many practitioners possess a general understanding of these changes, but few possess an in-depth understanding of the impact these new rules will have. This program got down to the brass tacks of what the new audit rules look like in action - at formation, during the audit process, and on appeal, so that you can make more out of your pre-game planning!

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Michael Sardar presented "Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices" at the Sid Kess's "Dealing with the IRS" seminar at Baruch College on Dec. 4.

Michael Sardar presented "Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices" at the Sid Kess's "Dealing with the IRS" seminar at Baruch College on Dec. 4.

In the event of a loss of client records or due to poor record keeping, a paid preparer may need to help his client reconstruct the records and/or make estimates. This session covered tips and ideas on how to handle such issues from tax-return  preparation through audit and will include a review of the Schedule C Form, common Schedule C pitfalls, and the best practices for how the tax return preparer and client can utilize estimates and reconstructions in these situations.  The session also addressed the Cohan rule and the AICPA Statement on Standards with respect to the use of estimates. 

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Michael Sardar moderated the panel "Ethical Obligations To Report Misconduct by Other Practitioners and Taxpayers" at the 2019 New England IRS Representation Conference in Uncasville, CT

Tax practitioners should be mindful of their ethical obligation to report tax-related misconduct under the internal revenue laws, the Model Rules of Professional Conduct, and Circular 230.  This group of experienced panelists examined when, whether, and how to complain about professional misconduct by private practice and government attorneys or the Court. The panelists also discussed when, whether, and how to report tax-related misconduct by unscrupulous tax professionals.

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Sharon L. McCarthy Moderated the Panel "Summons & Summons Enforcement" at the 2019 New England IRS Representation Conference in Uncasville, CT

Sharon L. McCarthy Moderated the Panel "Summons & Summons Enforcement" at the 2019 New England IRS Representation Conference in Uncasville, CT on November 22, 2019.

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Sharon L. McCarthy Participated on the Panel "IRS Enforcement Update" at the 2019 New England IRS Representation Conference in Uncasville, CT

Sharon L. McCarthy Participated on the Panel "IRS Enforcement Update" at the 2019 New England IRS Representation Conference in Uncasville, CT on November 22, 2019.

 

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Caroline D. Ciraolo Moderated "A Conversation with Nina Olson, Former National Taxpayer Advocate" at the 2019 New England IRS Representation Conference in Uncasville, CT

Caroline D. Ciraolo moderated "A Conversation with Nina Olson, Former National Taxpayer Advocate" at the 2019 New England IRS Representation Conference on November 22, 2019 in Uncasville, CT.

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Caroline D. Ciraolo Presented "Criminal Aspects of IRS Collection Cases" at the 2019 New England IRS Representation Conference in Uncasville, CT

Caroline D. Ciraolo participated on the panel "Criminal Aspects of IRS Collection Cases" at the 2019 New England IRS Representation Conference in Uncasville, CT, on November 22, 2019. 

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Stephen A. Josey Participated in the Panel Entitled "Give Me Back My Money: The Life of a Refund Suit," at the IRS Representation Conference on November 21, 2019

Stephen A. Josey participated in the panel entitled "Give Me Back My Money: The Life of a Refund Suit," at the IRS Representation Conference on November 21, 2019 in New Haven, CT.

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