A Special Tax Court Panel Keynote Session
(1 TAX CPE) (1 CLE)
Diana L. Leyden, United States Tax Court Special Trial Judge, Washington, D.C.; Rose E. Gole, Internal Revenue Service Office of Chief Counsel, Associate Area Counsel (SBSE), New York, NY; Laurie B. Kazenoff, Esq., former IRS Chief Counsel Senior Trial Attorney, Partner and Co-Chair of Tax Practice Group at Moritt Hock & Hamroff LLP, Garden City, NY; Robert M. Finkel, Esq., former IRS Chief Counsel Senior Trial Attorney, Partner and Co-Chair of Tax Practice Group at Moritt Hock & Hamroff LLP, New York, NY; Michelle E. Espey, Esq., Tax Practice Group at Moritt Hock & Hamroff LLP, Garden City, NY
You must attend this session for a full day's credit.
Tax practitioners who frequently handle Examinations or Appeals cases may not realize how important everything they do at those early stages can impact their client's rights and how receiving a Statutory Notice of Deficiency (SND) can change the game. Many perceive the U.S. Tax Court as a venue they will never have to see, so why worry about it? There is nothing worse than realizing after-the-fact that you defaulted your client's rights merely because you didn't understand the important role of the U.S. Tax Court and its rules of practice and procedure. We will address these issues including privilege, evidence issues that exist at early stages of a case, the role of statute extensions, whether or not to file a petition, addressing substantive and procedural issues when preparing a petition, rights to an Appeals Conference even when a case has been petitioned, rules of practice before the Tax Court, settlement conferences for docketed cases, what to do when the IRS wants to litigate your client's issue even if you don't.