The Four Acts of an IRS Controversy: Act I: The Roadmap for Handling a Challenging IRS Examination from a Tax Litigator’s Perspective
12:15 - 1:15 p.m. EST
Act I focuses on how to approach an IRS examination with an eye towards litigation, even when the chances of litigation are remote. In many instances, taxpayers are forced to litigation due to mistakes or an oversight that occurred during the planning stages of a transaction or during the IRS examination. On a combined basis, the panelists have been involved in over 150 tax litigation cases and will discuss how to plan for a tax controversy during the planning stages of a transaction as well as tactical decisions that must be considered during the audit. These issues include: (i) how to consider IRS audit issues during the planning stages; (ii) when do I need a Kovel agreement; (iii) what privileges and other protections do I have prior to and during the IRS audit; (iv) how to respond to the challenging IRS Information & Document Request, including the request to prepare summary materials for the IRS; and (v) when do I agree to disagree with IRS Exam.
Jones Day partners Chuck Hodges and Kathy Keneally, of counsel Karl Kellar, and counsel Antoinette Ellison will present.
This webinar is the first in a four part series. The topics and tentative schedule for the remaining webinars can be found below.
Act II: Uncommon Strategies for Dealing with the IRS Appeals Office Including Avoiding the Protest Route (May-June, 2019)
Act III: Alternative Dispute Resolution Techniques in Dealing with the IRS: Why Post-Appeals Mediation Works (Aug. 2019)
Act IV: Litigating a Federal Tax Case: Removing IRS’s Home Field Advantage (Oct.-Nov. 2019)
REGISTRATION & CLE CREDIT
Registration for this event is required.
This program has been approved for 1.00 hour of general credit by the State Bar of California and 1.00 hour of areas of professional practice credit (including transitional credit) by the New York State CLE Board. Jones Day is a State Bar of California MCLE approved provider, as well as an accredited provider in New York. Pennsylvania credit is not available for this program. Application for CLE credit in other states will be made as needed.