There is more than one way to get your client's case to the IRS Independent Office of Appeals. The taxpayer can file a protest with Appeals after an audit (i.e., "undocketed"), or they can request consideration by Appeals after filing a petition in the United States Tax Court pursuant to a Statutory Notice of Deficiency (i.e. "docketed"). Our final panel will review these procedures, outline the scope and standard of review, explain when a conference is granted with Appeals in a docketed case, and review the authority to settle under either scenario.
The IRS Representation Conference brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The Conference covers a wide range of representation issues, from procedural seminars to substantive programs, estate & gift issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.
This comprehensive, two full-day event focuses on the practical issues and how to handle them rather than theoretical issues.
View further details on the event here.
Please note: Enrolling in an individual session will grant you access to the entire two-day event.
Green & Sklarz LLC
Attorney at Law
jsklarz@gs-lawfirm.com
(203) 285-8545
Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs, including bankruptcy/bankruptcy litigation, creditor/debtor litigation, tax litigation, pension and employee benefits 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 and among bankruptcy law, tax law, and ERISA.
IRS
Acting Chief of Appeals, Independent Office of Appeals
Mr. Keyso is a long time veteran of the IRS, with more than 25 years of service. During his career, he has held numerous positions within the IRS, including serving as the IRS Chief of Staff, 18 years in various positions in the IRS Office of Chief Counsel, including as Associate Chief Counsel of the Income Tax and Accounting Division. Mr. Keyso also served as Special Counsel to the Chief Counsel and as an attorney in the Procedure and Administration Division. Before coming to Washington, DC, Mr. Keyso worked as a revenue agent in the former Newark, New Jersey District, where he later served as a technical advisor to the Chief, Examination Division. Since July 2017, Mr. Keyso has been the Deputy Chief of Appeals and acting Appeals Chief.
IRS
Senior Attorney
erika.b.cormier@irscounsel.treas.gov
Erika is an attorney at the IRS Office of Chief Counsel.
DLA Piper LLP
Partner
diana.erbsen@dlapiper.com
(212) 335-4572
Diana Erbsen has more than two decades of experience in the tax controversy area, where she focuses on federal, state, and local tax controversies, including criminal tax matters. Diana has significant experience representing clients in all aspects of sophisticated, challenging tax disputes. She has been recognized by the American College of Tax Counsel as a Fellow and is a frequent speaker at national tax conferences and forums.
From 2014 to 2017, Diana served as the Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice, a position to which President Barack Obama appointed her. In this role, Diana oversaw the Appellate Section (responsible for all appellate litigation, including to the Supreme Court), the Office of Review (responsible for civil settlements), and the Financial Litigation Unit (tasked with collecting judgments secured by the Trial Sections of the Tax Division). Additionally, Diana was actively involved in the management and operations of the Civil and Criminal Sections of the Tax Division and represented the DOJ on the Advisory Committee on Bankruptcy Rules. She was recognized in January 2017 by IRS Chief Counsel William Wilkins, with the Chief Counsel Award (the highest honor that can be conferred by that office) for her leadership and oversight of the Appellate Section. Her contributions to the precedent-setting Altera v. Commissioner case, a model for the government's defense of cases pending in the District Court and the Tax Court, were expressly noted.
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CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.
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