17th Annual Tax Controversy Forum 2025 – Track I (Presented by NYU School of Professional Studies)

Caroline D. Ciraolo, Esq., Partner | Kostelanetz

Caroline Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Michael J. Desmond, Esq., Member and Co-Chair of Tax Controversy Group | Miller & Chevalier, Chartered

Michael Desmond’s practice covers a broad range of federal tax matters with a focus on administrative tax policy, tax controversy, and litigation. He represents clients in approaches to the Internal Revenue Service (IRS) and the U.S. Department of the Treasury (Treasury) on administrative rulemaking matters and matters relating to tax administration and enforcement, seeking clarity on the application of federal tax laws. He also represents clients before the examination divisions of the IRS, the IRS Independent Office of Appeals, and in the U.S. Tax Court, federal district courts, the Court of Federal Claims, and federal courts of appeal. Mike is described by clients in Chambers USA as “very smart, strategic, and knowledgeable of tax law,” “responsive and insightful,” noting that “[h]is knowledge of complex matters is incredibly valuable.”

Sharon Katz-Pearlman, Esq., Shareholder | Greenberg Traurig

Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, and other taxpayers, before the IRS. She represents clients from the pre-exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. In addition, Sharon has represented clients using the full range of IRS Alternative Dispute Resolution techniques which are available to taxpayers, and advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs.

Loren C. Ponds, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

Loren Ponds leverages her extensive tax policy experience to provide strategic counsel to clients across industries on a variety of legislative and regulatory issues. She also frequently advises on technical matters related to international tax, including controversy and transfer pricing.

Scott Levine, Esq., Former Deputy Assistant Secretary | International Tax Affairs

Scott Levine the Former Deputy Assistant Secretary (International Tax Affairs) and Tax partner in Baker McKenzie’s Tax Practice Group, based in the Firm’s DC office.
Prior to joining the Firm, Scott most recently served as the Deputy Assistant Secretary (International Tax Affairs) in the US Department of the Treasury, where he led the Office of Tax Policy’s work on international affairs, including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2.

Joshua Odintz, Esq., Partner | Holland & Knight

Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters. He is a co-leader of the Public Policy & Regulation Group’s Tax Policy Team.

Terry Lemons, Former Communications & Liaison Chief | Internal Revenue Service

Terry Lemons spent more than 26 years at the IRS in a variety of roles overseeing the agency’s communications efforts. Before retiring from the government in February, Lemons worked 11 years as the IRS Chief of Communications and Liaison, where he served as a principal advisor to the Commissioner and IRS leadership. In this role, he navigated some of the toughest communications scenarios in government while leading a 325-person team and overseeing the agency’s work with the tax professional community, Congress, the news media as well as internal communications to 100,000 employees.

Emily P. Hughes, PC, Esq. Partner | Kirkland & Ellis

Emily P. Hughes is a litigation partner in the Washington, D.C., office of Kirkland & Ellis LLP. Her practice focuses on counseling and defense of companies, partnerships, individuals, and non-profits in civil and criminal matters, particularly where tax or other complex financial matters are involved. Emily is a problem solver who is uniquely attuned to the needs and issues confronting closely-held enterprises, including private equity sponsors and their founders and shareholders in private companies.

Elizabeth Askey, Esq., Chief | IRS Independent Office of Appeals

Liz Askey is Chief of the Independent Office of Appeals at the Internal Revenue Service (IRS). In this role, she provides leadership and direction over nationwide programs designed to fairly and impartially resolve tax controversies without litigation on the behalf of the federal government and taxpayers.

Jennifer Breen, Esq., Partner | Morgan Lewis & Bockius

Jennifer Breen represents domestic and multinational businesses, large partnerships, high-net-worth individuals, and family offices on tax controversy and Internal Revenue Service (IRS) administrative matters. She also counsels professional services firms, investment fund managers, and private equity firms on partnership tax issues. With decades of experience spanning government service, a “Big Four” public accounting firm, and in-house as the director of tax controversy for a large multinational corporation, Jennifer offers a rare perspective in her invaluable ability to see tax issues from multiple vantage points.

The Hon. Elizabeth A. Copeland, Judge | United States Tax Court

Judge Copeland was born in Colorado. She earned her Bachelor of Business Administration, cum laude, from the University of Texas at Austin, and her Juris Doctor from the University of Texas School of Law. A Certified Public Accountant (Texas, 1988), she was admitted to the State Bar of Texas in 1992.

Diana L. Erbsen, Esq., Partner | DLA Piper

Diana Erbsen has more than two decades of experience in tax controversy, representing clients in all aspects of sophisticated, challenging, and often high stakes tax disputes. In 2014, Diana was appointed to the position of Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice by President Obama. Following the end of the administration on January 20, 2017, Diana returned to DLA Piper as a partner.

Daniel N. Price, Esq. | Law Offices of Daniel N. Price

Dan’s legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Dan has had unique experience with tax controversy and tax administration. In February 2025, the American College of Tax Counsel elected Dan as a fellow (see press release) recognizing his experience practicing tax law.

Kaitlyn Loughner, Esq., CPA, Partner | Frost Law

Kaitlyn’s experience as a Certified Public Accountant and a tax attorney gives her a unique perspective on domestic and international tax compliance issues for individuals and businesses including streamlined compliance for individuals, corporations, partnerships, and limited liability companies. Kaitlyn handles cases with issues involving individual and corporate income tax, international tax compliance, IRS and State tax audits, tax relief and collection — including sales and use taxes, admissions and amusement tax, and withholding tax.

Guinevere M. Moore, Esq., Managing Member | Moore Tax Law Group

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies. She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with an office in Chicago.

Carlos F. Ortiz, Esq., Partner | BakerHostetler

A seasoned trial attorney, recognized by Law360 as a “Legal Lion of the Week” and by AmLaw’s Litigation Daily as a “Litigator of the Week,” Carlos Ortiz focuses his practice on high-risk tax controversies, anti-corruption (Foreign Corrupt Practices Act (FCPA) and Foreign Extortion Protection Act (FEPA)), offshore tax issues, anti-money laundering, e-commerce fraud and healthcare fraud, as well as allegations of fraud against government agencies and financial institutions. He has extensive experience representing U.S.- and foreign-based corporations and individuals in the pharmaceutical, financial services, healthcare, aerospace, energy and telecommunications industries in connection with matters before enforcement and regulatory agencies, including the U.S. Department of Justice (DOJ), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC) and various state attorneys general. Over his career in private practice, he has secured the declination of criminal charges for corporate and individual clients. On several occasions, he has prevented the referral of charges for the target of criminal tax investigations.

Rod J. Rosenstein, Esq., Partner | King & Spalding

As Deputy Attorney General under President Donald J. Trump, Rod J. Rosenstein supervised all Department of Justice components. He also held senior political appointments under Presidents George W. Bush and Barack Obama, as U.S. Attorney for Maryland from 2005 to 2017 and Principal Deputy Assistant Attorney General for the Tax Division from 2001 to 2005. A skilled trial and appellate lawyer, Rod personally represented the United States in 23 jury trials and argued 21 civil and criminal appeals in appellate courts and the Supreme Court. He helps clients with sensitive regulatory, enforcement and litigation challenges, including civil and criminal cases, congressional investigations, crisis management, national security and cyber issues, higher education inquiries, tax controversies, and compliance matters.

Don Fort, CPA, Director of Investigations | Kostelanetz

John D. (Don) Fort is the Director of Investigations at Kostelanetz LLP, and the former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and has an extensive network of connections both within the government and in private industry.

Guy Ficco, Chief, Criminal Investigation Division | Internal Revenue Service

Guy Ficco has been serving as the Chief of the IRS Criminal Investigation (CI) Division since April 1, 2024. A 29-year veteran of the IRS, Ficco began his career in 1995 as a student co-op in the New York Field Office. Over the years, he has held numerous leadership positions, including Deputy Chief of CI, Executive Director of Global Operations, and Special Agent in Charge of the Philadelphia Field Office. He is a Certified Fraud Examiner and holds a bachelor’s degree in business administration with a concentration in accounting from Dominican University in New York.

Ian M. Comisky, Esq., Partner | Fox Rothschild

Ian has more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense, and complex corporate and commercial disputes.

Jenny G. Sugar, Esq., Member | Moore & Van Allen

Jenny Sugar is a member of Moore & Van Allen’s Litigation group. She represents corporations and executives in white collar criminal and government enforcement investigations, proceedings, and trials.

As a federal prosecutor for more than two decades, Jenny investigated, prosecuted, and oversaw matters involving a broad range of complex financial crimes, including investment fraud, bank fraud, wire fraud, tax fraud, Ponzi schemes, money laundering, and abuse of government funding programs, as well as health care fraud matters.

Dean Zerbe, Esq. Partner | Zerbe, Miller, Fingeret, Frank & Jadav

Dean Zerbe was Senior Counsel and Tax Counsel for the Chairman of the Senate Finance Committee, Senator Charles E. Grassley, 2001-2008. At the direction of Chairman Grassley, Dean was the counsel responsible for the modern IRS whistleblower law – signed into law in 2006 — which established the IRS Whistleblower Office and created an award program for tax whistleblowers. Dean “wrote the law” when it comes to the IRS whistleblower office and reward program.

Randall M. Fox, Esq., Partner | Kirby McInerney

Randall M. Fox is a partner in our New York office who represents whistleblowers in False Claims Act and IRS, SEC, and CFTC matters about tax, healthcare, procurement, and investment frauds. He was named the Whistleblower Lawyer of the Year for 2021 by The Anti-Fraud Coalition.

Larry A. Campagna, Esq., Managing Shareholder | Chamberlain, Hrdlicka, White, Williams & Aughtry, PC

Larry Campagna has an established reputation as an authoritative litigator in matters of business litigation, white-collar criminal defense, and particularly in federal, state and local tax controversies. For more than 45 years, he has resolved thousands of civil and criminal litigation matters, many of which involved sophisticated and complex legal issues that established precedent in courts at the federal, state and local levels.

Erin M. Collins, Esq., National Taxpayer Advocate | Internal Revenue Service

In March 2020, Erin M. Collins was appointed by Secretary Mnuchin as the National Taxpayer Advocate and she now oversees the Office of the Taxpayer Advocate Service (TAS). She is the “Voice of the Taxpayer” within the IRS and before Congress. TAS serves as a “safety net” for taxpayers by advocating for resolution of individual and business taxpayer issues within the IRS. She identifies and works toward systemic changes for all taxpayers while protecting Taxpayer Rights. TAS also oversees the Low Income Taxpayer Clinic (LITC) federal grant program and the Taxpayer Advocacy Panel (TAP). As part of her Annual Report to Congress, she makes administrative and legislative changes to protect taxpayer rights and works toward improving the quality of taxpayer service and tax administration by being an independent voice inside the IRS. As the National Taxpayer Advocate, Erin testifies before the Senate Finance Committee, the U.S. House of Representatives Ways and Means Committee Oversight Subcommittee, and the Senate Appropriations Subcommittee on topics concerning tax administration and taxpayer rights.

E. Martin Davidoff, CPA, Esq., Partner-in-Charge | National Tax Controversy Practice, Prager Metis

E. Martin Davidoff, CPA, Esq., brings over 30 years of experience as both an accountant and attorney. He has authored 30 articles in CPA Magazine, serving as its IRS Representation Advisor. He is the founder of accounting and law firms dedicated primarily to taxes, tax advice, and tax preparation, with a mission to provide clients with peace of mind. Martin currently serves as the National Managing Partner of the Tax Controversy team at Prager Metis CPAs, LLC. For more information, please visit his websites.

Robert J. Fedor, Esq., Managing Member | Robert J. Fedor, Esq. LLC

Managing Member since 1995.

With over 35 years of experience in representing businesses and individuals before all types of Internal Revenue Service proceedings, whether it be administrative or before the United States Bankruptcy Court, the United States Tax Court, one of the United States District Courts or a U.S. Court of Appeals, Robert J. Fedor leads this 8-member firm with his expertise in tax and tax-related matters. Mr. Fedor’s experience has provided him with a vast understanding of tax-related issues, spanning from tax litigation, IRS collections, criminal tax defense, as well as other tax-related controversy matters.

The Hon. Jennifer E. Siegel, Special Trial Judge | United States Tax Court

Special Trial Judge Siegel holds a B.A. from Barnard College, an M.B.A. from the Drucker School of Management at Claremont Graduate University, a J.D. from the University of San Francisco School of Law, and an LL.M. in Taxation from New York University School of Law.

Moderator: John Colvin, Esq., Partner |Colvin + Hallett

John draws from his almost three decades of practice and experience in tax law to develop legal theories and strategies in defense of his clients. John keeps a close eye on developments in the tax law, which enables him to provide his clients an unparalleled awareness of current developments and their implications.

Richard J. Sapinski, Esq. | Partner, Sills Cummis & Gross PC

Richard J. Sapinski is Co-Chair of the Firm’s Tax Fraud and Controversy Practice Group. His practice involves white collar criminal defense on both federal and state levels and civil and criminal tax litigation, as well as international tax reporting and compliance issues. Before entering private practice, Mr. Sapinski was employed by the IRS Office of the District Counsel as a Trial Attorney (1977-1984) and later as a Special Trial Attorney (international) with the IRS Office of Regional Counsel, Mid-Atlantic Region (1985-1987). In the latter position, Mr. Sapinski was assigned responsibility for litigating in the United States Tax Court on behalf of the Commissioner of Internal Revenue in large and sensitive cases and for assisting IRS international examiners in developing international tax issues for litigation.

He litigates matters in the United States District Court, U.S. Tax Court and the Superior Court and Tax Court of New Jersey and the Federal and State Appellate Courts. He also represents professionals before disciplinary and licensing boards and handles administrative matters involving the Examination, Collection and Criminal Investigation divisions of the Internal Revenue Service and their state counterparts.

Benjamin L. Tompkins, Esq., Partner | Nardiello Turanchik Tompkins

Ben Tompkins works closely with individuals, companies and exempt organizations, providing guidance and counsel in all aspects of civil and criminal tax litigation, as well as providing counsel to those facing tax examinations, collections or other administrative investigations and proceedings. Ben focuses on tax controversies, white collar criminal defense, and other government investigations and has extensive experience successfully defending clients in all types of complex litigation in federal and state courts nationwide.

Melissa L. Wiley, Esq., Partner | Kostelanetz

Melissa brings more than two decades of civil tax controversy and litigation experience to Kostelanetz, augmenting the firm’s stellar reputation as a premier civil and criminal tax controversy boutique.

Moderator: George A. Hani, Esq., Member | Miller & Chevalier

George Hani concentrates his practice on the resolution of tax controversies at the administrative level, with a particular focus on tax accounting issues. He has represented clients in traditional Internal Revenue Service (IRS) examinations and administrative appeals, as well as in connection with a number of IRS dispute resolution programs, such as the Advanced Pricing Agreement (APA) program, the Pre-Filing Agreement (PFA) program, the Compliance Assurance Process (CAP), Fast Track Appeals and Accelerated Issue Resolution (AIR). Mr. Hani has assisted taxpayers to secure consents for changes in methods of accounting, private letter rulings and favorable technical advice memos from the IRS National Office. When necessary, he has represented taxpayers in United States Tax Court and in federal district courts. He has also represented individuals in collection matters, criminal investigations and the off-shore voluntary disclosure programs. Mr. Hani was described by clients in Chambers USA as “a true subject-matter and technical expert, from a regulations angle,” who also noted “he knows all the IRS rules and the best way to tackle things, on the audit side.” Clients said “[h]e is super smart, thorough, thoughtful, easy to work with and he meets deadlines,” and “excellent with tax controversy and tax accounting.”

Michelle Abroms Levin, Esq., Shareholder | Dentons Sirote

Michelle Abroms Levin is a shareholder in Dentons Sirote’s Huntsville, Alabama office, where she is a member of the Tax practice group and manages the Huntsville office. She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, federal district court and the Courts of Appeals. Michelle has secured major victories for her clients in the Eleventh Circuit, Fifth Circuit, and Tax Court, elevating important Administrative Procedure Act issues in the tax controversy context. Her experience includes a wide range of complex tax issues. Michelle also counsels clients in tax and business planning. She works with clients to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels.

Josh O. Ungerman, Esq., CPA, Partner | Meadows, Collier, Reed, Cousins, Crouch & Ungerman

Mr. Ungerman’s experience as a former IRS Senior Trial Attorney and Department of Justice (DOJ) Special Assistant U.S. Attorney are invaluable in helping clients with IRS civil tax and criminal tax controversy matters at all levels along with tax and estate planning. The tax and estate matters in which Josh is involved are typically very complex from both a factual and legal perspective. These matters often require legal and accounting skills. Josh is also a Certified Public Accountant.

Phillip Colasanto, Esq., Senior Associate | Withers Bergman

Phillip is a senior associate in the private client and tax team. His practice is focused on domestic and international tax controversy and compliance matters. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts. He has represented clients from audit through trial and at the appellate level.

Moderator: Miri Forster, Esq., Partner and National Tax Controversy Leader | EisnerAmper

Miri Forster is a Partner and National Leader of the Tax Controversy & Dispute Resolution practice group, specializing in providing tax dispute resolution services to public and private corporations, partnerships and high net worth individuals on a wide range of technical and procedural issues. She has over 20 years of IRS practice, procedure, and tax controversy experience.

Aaron Esman, Esq. | Member, Ziering & Esman

Aaron M. Esman, Esq., is a founding member of Ziering & Esman PLLC, a New York-based law firm specializing in tax controversy matters. Established in 2025 alongside co-founder Zhanna A. Ziering, the firm is dedicated to providing high-quality representation in tax audits, investigations, appeals, and litigation.

Michael Sardar, Esq., Partner | Kostelanetz

Michael Sardar, Esq., is a partner at Kostelanetz LLP in New York City, where he focuses on tax controversy and white-collar criminal defense. He represents clients in all stages of civil and criminal tax disputes before the IRS, state tax authorities, the Department of Justice, and local prosecutors. His practice includes advising on foreign bank and asset reporting compliance, voluntary disclosures of unreported income, and repatriation of offshore assets through programs like the IRS Offshore Voluntary Disclosure Program and Streamlined Compliance Procedures.

Christopher S. Rizek, Esq., Partner | Holland & Knight

Christopher S. Rizek, Esq., is a partner at Holland & Knight LLP, based in Washington, D.C., where he plays a pivotal role in the firm’s Tax, Executive Compensation and Benefits Practice and is a key member of its nationwide Tax Controversy Team. With a distinguished career spanning both government service and private practice, Mr. Rizek brings extensive experience in federal civil and criminal tax controversy matters.

Moderator: Michel R. Stein, Esq., Principal | Hochman Salkin Toscher Perez, PC

Michel R. Stein, Esq. is a principal at Hochman Salkin Toscher Perez P.C., a Beverly Hills-based law firm renowned for its expertise in tax controversy and litigation. With over 25 years of experience, Mr. Stein specializes in representing individuals, businesses, and corporations in complex tax matters, including civil tax examinations, administrative appeals, and criminal tax investigations.

Zhanna A. Ziering, Esq., Managing Member | Ziering & Esman

Zhanna A. Ziering, Esq. is the Managing Member and co-founder of Ziering & Esman PLLC, a New York-based law firm established in 2025 that specializes in tax controversy and litigation. With over 15 years of experience, Ms. Ziering represents individual and corporate clients in complex civil and criminal tax disputes involving federal and state authorities, including the IRS and the Department of Justice.

Eric Green, Esq., Founding Partner | Green & Sklarz

Eric L. Green, Esq. is the founding partner of Green & Sklarz LLC, a boutique tax law firm headquartered in New Haven, Connecticut, with additional offices in Stamford, West Hartford, and New York City . His practice concentrates on representing clients in both civil and criminal tax matters before the Internal Revenue Service (IRS), the Department of Justice Tax Division, and various state tax authorities

Eman Cuyler, Esq., Associate | Skadden Arps Slate Meagher & Flom

Eman Cuyler, Esq. is an associate in the Tax Group at Skadden, Arps, Slate, Meagher & Flom LLP, based in Washington, D.C. Her practice focuses on federal tax controversy and corporate tax planning for multinational corporations. She advises clients on complex tax issues, including transfer pricing, international tax, accounting methods, and tax procedures. Ms. Cuyler represents clients in all stages of tax disputes, from audits and administrative appeals to litigation, and provides counsel on domestic and international transactions, such as mergers, acquisitions, and reorganizations .

Fran Obeid, Esq., Founder | MFO LAW, PC

Fran Obeid, Esq. is the founder and principal of MFO LAW, P.C., a New York City-based boutique law firm specializing in civil and criminal tax controversy. With over two decades of experience, Ms. Obeid represents individual and corporate clients in complex matters involving the Internal Revenue Service (IRS), state and city tax agencies, the U.S. Department of Justice Tax Division, U.S. Attorney’s Offices, District Attorney’s Offices, and the New York State Attorney General.

Moderator: Joshua D. Smeltzer, Esq., Partner | Gray Reed

Joshua D. Smeltzer, Esq. is a Partner at Gray Reed, based in Dallas, Texas, where he co-chairs the firm’s Blockchain and Digital Asset practice. He specializes in defending clients in all stages of civil and criminal tax proceedings, including sensitive audits and examinations. His clientele includes corporations, complex partnerships, family offices, estates and trusts, and high-net-worth individuals across various industries such as real estate, energy, insurance, private equity, and digital assets.

Jonathan Kalinski, Esq., Principal | Hochman Salkin Toscher Perez, PC

Jonathan Kalinski, Esq. is a Principal at Hochman Salkin Toscher Perez P.C., a Beverly Hills-based law firm renowned for its expertise in civil and criminal tax controversies. With a focus on complex tax matters, Mr. Kalinski represents a diverse clientele, including individuals, corporations, partnerships, limited liability companies, and trusts and estates, in both federal and state tax disputes.

Darren John Guillot, National Director | alliantGroup

Darren John Guillot serves as the National Director at alliantgroup, based in Washington, D.C. With a distinguished 36-year tenure at the Internal Revenue Service (IRS), Mr. Guillot brings extensive experience in tax administration and enforcement to his current role, where he assists small and medium-sized businesses in navigating complex tax systems and securing valuable incentives and credits.

Mary E. Wood, Esq., Partner | Meadows, Collier, Reed, Cousins, Crouch & Ungerman

Mary E. Wood, Esq. is a Partner at Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P. in Dallas, Texas. Her legal practice focuses on federal and state tax controversies, white-collar criminal defense, and complex commercial litigation.

Moderator: Pamela Grewal, Esq., Managing Director | Andersen Tax
Pamela Grewal is a managing director in the US National Tax practice, Pamela draws on over 17 years of government experience to assist clients in navigating federal tax controversy matters.

Thomas A. Cullinan, Esq., Shareholder | Chamberlain, Hrdlicka, White, Williams & Aughtry, PC

Tom Cullinan is a Shareholder in the Firm’s Atlanta office. Tom joined the Firm from the IRS, where he served as the Counselor to the IRS Commissioner and then as the acting IRS Chief of Staff.

Christopher M. Ferguson, Esq., Partner | Kostelanetz

Christopher M. Ferguson, Esq. is a Partner at Kostelanetz LLP in New York City, where he brings over two decades of experience in white collar criminal defense, civil and criminal tax controversies, and regulatory enforcement matters. He represents clients in federal and state courts, as well as before agencies such as the U.S. Department of Justice, Internal Revenue Service, Securities and Exchange Commission, FINRA, and various New York state and city entities.

Eric Hylton, National Director | alliantGroup

Eric Hylton is the National Director of Compliance at alliantgroup, based in Washington, D.C. With over 30 years of experience at the Internal Revenue Service (IRS), he brings extensive expertise in tax enforcement and compliance to his role, assisting U.S. businesses in navigating complex tax matters.

Daniel Mayo, Esq., Partner | WithumSmith+Brown, PC

Daniel Mayo, Esq. is a Partner at WithumSmith+Brown, PC, based in Red Bank, New Jersey, where he leads the firm’s National Tax Services practice. With over 25 years of experience in federal, international, and financial products taxation, Mr. Mayo advises clients on structuring transactions to minimize federal income taxes. His expertise encompasses mergers and acquisitions, capital markets, and cross-border transactions.

DAY 1, THURSDAY, JUNE 26, 2025

WELCOME – OPENING REMARKS | 8:00am – 8:05am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I | 8:05am – 8:30am

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the Internal Revenue Service (IRS) and Justice Department (DOJ) have been pursuing new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. In recent weeks, however, the future and efficacy of those programs have been called into question as resource constraints are being imposed across the federal government. These panels, including three afternoon breakout sessions, provide a comprehensive update on developments and priorities across various functions of the Treasury Department, Justice Department Tax Division and IRS relating to enforcement of and compliance with our Nation’s tax laws.

Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC

Michael J. Desmond, Esq., Member and Co-Chair of Tax Controversy Group, Miller & Chevalier, Chartered, Washington, DC

WHAT’S NEXT FOR THE IRS? A BUDGET AND POLICY PERSPECTIVE | 8:30am – 9:20am

At our 2024 program, the IRS’ Operating Division Commissioners provided an update on a new leadership structure at the IRS designed to align its enforcement priorities with a surge in funding provided for under the Inflation Reduction Act. That enforcement focus has since flipped, with a turnover in leadership, a major curtailment of funding and staff, and projections for further material resource reductions. The future of IRS enforcement is now tied up with broader legislative priorities, including extension of the individual and various expiring business provisions of the Tax Cuts and Jobs Act and an uncertain future for the IRS. Meanwhile, the rest of the world is rapidly moving forward with implementation of the Organization for Economic Co-operation and Development’s (OECD) Global Anti-Base Erosion Rules (GloBE) (Pillar 2), with the United States sitting on the sidelines for the moment on these global tax initiatives. Our panel of experts all work at the intersection of tax administration and policy and they provide insight on what the future might hold for tax enforcement, both domestically and around the world.

Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY

Loren C. Ponds, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, Washington, DC

Scott Levine, Esq., Former Deputy Assistant Secretary, International Tax Affairs, Washington, DC

Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC

Terry Lemons, Former Communications & Liaison Chief, Internal Revenue Service, Washington, DC

Break | 9:20am – 9:30am

UPDATE FROM THE IRS INDEPENDENT OFFICE OF APPEALS | 9:30am – 9:55am

The IRS Independent Office of Appeals (Appeals) has always served a critical role in resolving tax disputes short of litigation, considering hazards of litigation for taxpayers and the IRS alike. Over the past two years, Appeals has been calibrating a renewed focus on alternative dispute resolution (ADR) procedures as a tool to complement its traditional conference procedures. In the current resource constrained environment, with a large inventory of complex cases pending in Exam, Appeals and in litigation, Appeals in general and ADR programs in particular are likely to play an increasingly important role in minimizing delay in dispute resolution. The Chief of IRS Appeals has been invited to give her perspective on ADR and to provide an update on Appeals activities in general.

Moderator: Emily P. Hughes, PC, Esq., Partner, Kirkland & Ellis, Washington, DC

Elizabeth Askey, Esq., Chief, IRS Independent Office of Appeals, Washington, DC (invited)

Break | 9:55am – 10:05am

UPDATE FROM THE U.S. TAX COURT AND THE IRS OFFICE OF CHIEF COUNSEL | 10:05am – 10:50am

The Tax Court and IRS Office of Chief Counsel sit at the center of tax controversy, with more than 25 thousand pending cases that range from multibillion dollar transfer pricing disputes to collection due process matters with relatively small amounts at stake but often presenting important questions of law. Decisions from the Tax Court have broad consequences across the federal tax system. This panel provides insight into cases pending with the Tax Court and matters being worked by Chief Counsel that may be on their way to the Court. The Deputy Chief Counsel (Operations) has also been invited to provide an update on Counsel activities including litigation in Tax Court, prospects for case resolution in a resource constrained environment and the role of field counsel attorneys in advising Exam, Appeals and other IRS functions

Moderator: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC

The Hon. Elizabeth A. Copeland, Judge, United States Tax Court, Washington, DC (invited)

Audrey M. Morris, Esq., Deputy Chief Counsel (Operations), Office of Chief Counsel, Internal Revenue Service, Washington, DC (invited)

Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY

Break | 10:50am – 11:00am

PSYCHOLOGY AND TAX ENFORCEMENT | 11:00am – 12:00pm

Psychological issues are an often-overlooked factor in many tax disputes, particularly but not only for individual taxpayers. These issues often create or magnify tax compliance problems such as non-filing, non-payment, and an impaired ability to interact with the IRS to resolve or address a tax dispute. Properly explained and understood, these issues can also provide a basis for penalty relief, late filing relief, late election relief, and other relief. This panel considers the impact of psychological issues on tax compliance and enforcement, including the use of experts.

Moderator: Daniel N. Price, Esq., Law Offices of Daniel N. Price, San Antonio, TX

Kaitlyn Loughner, Esq., CPA, Partner, Frost Law, Annapolis, MD

Guinevere M. Moore, Esq., Managing Member, Moore Tax Law Group, Chicago, IL

Carlos F. Ortiz, Esq., Partner, BakerHostetler, New York, NY

Russell Wade, Psychotherapist, Russell l Wade, ACSW LICSW, Washington, DC

Lunch | 12:00pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK I

FREEDOM OF INFORMATION ACT REQUESTS: STRATEGIC CONSIDERATIONS FROM PRE-EXAM THROUGH LITIGATION

Transparency in its operations and activities is a hallmark of the federal government in general and the tax system in particular. This helps to ensure that development and enforcement of the tax law are transparent and helps to assure taxpayers that it is being uniformly and consistently applied. The Freedom of Information Act (FOIA) is an important tool for taxpayers and their advisors to access that transparency, both in development of the law through FOIA requests for formal and informal guidance background files and in enforcement of the law through FOIA requests for audit and other taxpayer-specific files. This panel discusses strategic considerations around whether and when to make a FOIA request and provides practical insight on how to make and advance those requests through the IRS, the administrative appeal process and in court.

Moderator: John Colvin, Esq., Partner, Colvin + Hallett, Seattle, WA

Richard J. Sapinski, Esq., Partner, Sills Cummis & Gross PC, Newark, NJ

Benjamin L. Tompkins, Esq., Partner, Nardiello Turanchik Tompkins, Washington, DC

Melissa L. Wiley, Esq., Partner, Kostelanetz, Washington, DC

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

TRACK I

MANAGING STATUTES OF LIMITATION

Practitioners are generally familiar with the three-year period the IRS has to assess a tax deficiency, the ten-year period the IRS has to collect an assessed tax and the applicable periods for filing administrative refund claims and refund actions based on those claims. Beyond these general limitation periods is a growing web of exceptions and overrides, the application of which can be of critical importance for taxpayers in deciding how to handle a tax dispute. Most often, limitations period considerations arise when a taxpayer is asked to extend the IRS’ assessment period, either to provide more time for the IRS to complete an examination or to take a dispute to IRS Appeals. This panel provides an overview of key exceptions to the general limitations periods in the Code, identifies potential traps for the unwary (and the wary) and highlights strategic considerations including when to grant or not grant an IRS extension request and circumstances where a restricted consent should be considered and might be granted.

Moderator: George A. Hani, Esq., Member, Miller & Chevalier, Washington, DC

Michelle Abroms Levin, Esq., Shareholder, Dentons Sirote, Huntsville, AL

Josh O. Ungerman, Esq., CPA, Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX

Phillip Colasanto, Esq., Senior Associate, Withers Bergman, New York, NY

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20pm – 4:10pm

TRACK I

SECURING RELIEF FROM LATE ELECTIONS, 9100 AND BEYOND

Taxpayers often fail to make timely elections, sometimes due to input—or the lack thereof—from a tax professional. With various limits and conditions, relief from certain missed election is available through regulations, commonly known as “section 9100 relief.” Two types of relief are offered by Treas. Regs. §§ 301.9100-1 through -3: Automatic relief and nonautomatic relief. This panel discusses the types of missed elections eligible for section 9100 relief, provides insight on the circumstances under which such relief may be granted or denied, and provides practical tips on how to prepare and present requests for section 9100 relief.

Moderator: Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY

Aaron Esman, Esq., Member, Ziering & Esman, New York, NY

Michael Sardar, Esq., Partner, Kostelanetz, New York, NY

Christopher S. Rizek, Esq., Partner, Holland & Knight, Washington, DC

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30pm – 5:30pm

TRACK IAVOIDING AND ABATING CIVIL TAX PENALTIES

The US tax system is based on “voluntary compliance,” meaning that taxpayers self-assess their liabilities on an annual basis and pay voluntarily. However, the IRS has several methods to encourage taxpayer compliance, such as passport revocation and criminal prosecution. The most frequent mechanism used is assessing penalties. This panel provides an overview of common accuracy-related, information reporting and other penalties and defenses thereto. This panel also provides insight on handling penalties on audit, in administrative appeals, and in litigation.

Moderator: Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

Zhanna A. Ziering, Esq., Managing Member, Ziering & Esman, New York, NY

Eric Green, Esq., Founding Partner, Green & Sklarz, New Haven, CT

Eman Cuyler, Esq., Associate, Skadden Arps Slate Meagher & Flom, Washington, DC

Fran Obeid, Esq., Founder, MFO LAW, PC, New York, NY]

DAY 2, FRIDAY, JUNE 27, 2025

TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II | 8:30am – 8:55am

UPDATE FROM THE TAX DIVISION, US DEPARTMENT OF JUSTICE

The Tax Division is going through a historic change in leadership and is the subject of ongoing discussions on its role and placement in tax administration. Meanwhile, along with other federal agencies, the Tax Division is dealing with a curtailment of resources while also absorbing an increase in the number of tax cases filed in refund, bankruptcy and other courts around the country. The Tax Division is also responsible for representing the United States in the various courts of appeal on cases involving tax at a dynamic time for important issues such as the standard for review of agency rulemaking. This interview provides an update on these and other important topics.

Moderator: Rod J. Rosenstein, Esq., Partner, King & Spalding, Washington, DC

Representative, Tax Division, US Department of Justice, Washington, DC (to be invited)

Break | 8:55am – 9:05am

CRIMINAL TAX ENFORCEMENT UPDATE | 9:05am – 10:05am

Criminal tax cases impact tax enforcement and administration far beyond the cases charged and tried every year, sending a signal to taxpayers and practitioners of areas of compliance that are a particular focus for the IRS. In a resource constrained environment, this signal could be more important than ever, as practitioners gage the future of tax compliance and enforcement. This panel provides inside perspective on the status of IRS criminal investigations and what to expect going forward.

Moderator: Don Fort, CPA, Director of Investigations, Kostelanetz, Washington, DC

Guy Ficco, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC (invited)

Representative, Tax Division, US Department of Justice, Washington, DC (to be invited)

Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA

Jenny G. Sugar, Esq., Member, Moore & Van Allen, Charlotte, NC

Break | 10:05am – 10:20am

IRS WHISTLEBLOWER OFFICE UPDATE | 10:20am – 10:45am

With the enactment of recent changes to section 7623, claims for whistleblower awards have skyrocketed and the IRS Whistleblower Office has a full plate of work: processing new submissions; managing open claims and issuing awards. To ensure it is successfully meeting these challenges, the Whistleblower Office has embarked on an ambitious Whistleblower Program Improvement Plan. Key goals of the plan include: increasing high-value claims coming in; improving the Whistleblower’s Office ability to identify such claims; and better tracking of such claims through improved systems—and efforts to pay awards sooner. This panel provides an update from the IRS Whistleblower Office on recent reform efforts, highlights issues that the IRS is particularly interested in hearing more about from whistleblowers, what makes for a good whistleblower submission, as well as touches on recent court decisions addressing this important practice area.

Moderator: Dean Zerbe, Esq., Partner, Zerbe, Miller, Fingeret, Frank & Jadav, Houston, TX

John W. Hinman, Director, Whistleblower Office, Internal Revenue Service, Washington, DC (invited)

Randall M. Fox, Esq., Partner, Kirby McInerney, New York, NY

Break | 10:45am – 10:55am

TAXPAYER ADVOCATE UPDATE | 10:55am – 11:25am

Erin Collins became the National Taxpayer Advocate (“NTA”) on March 30, 2020, at the outset of the COVID-19 pandemic. With the IRS pushed to its breaking point by the pandemic and now facing the challenge of a resource constrained environment), Collins and her team continue their dual focus on addressing systemic issues (of which there are many) and handling individual taxpayer cases (of which there are many more). Hear about the lessons learned over Collins’ past five years in the role and her vision for the future of the Taxpayer Advocate Service.

Moderator: Larry A. Campagna, Esq., Managing Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Houston, TX

Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC (invited)

Lunch | 12:20pm – 1:30pm

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK I

CRYPTO TAX ENFORCEMENT

The cryptocurrency industry is constantly changing and its underlying technologies are undeniably confusing for tax administrators and taxpayers alike. Faced with these obstacles, the IRS has issued informal guidance on discrete and nuanced tax issues and added questions about digital asset transactions to entity tax returns, Treasury has proposed new information reporting rules, and regulatory scrutiny is tightening from all directions. This panel discusses the latest issues involving digital assets and highlights important considerations for tax practitioners.

Moderator: Michelle F. Schwerin, Esq., CPA, Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO

Manny Muriel, MBA, EA, Partner, Bishop Muriel & Weirauch, East Islip, NY

James Creech, Esq., Director, Baker Tilly, San Francisco, CA

Jason Schwartz, Esq., Partner, Fried, Frank, Harris, Shriver & Jacobson, Washington, DC

Break | 2:20pm – 2:40pm

BREAK OUT SESSIONS | 2:40pm – 3:30pm

TRACK I

WHO PAYS? THIRD-PARTY RESPONSIBILITY IN TAX COLLECTION

Transferee liability involves situations where a third party can be held liable for the tax liability of another and often, although by no means only, arises in the procedural context of a determination made under the transferee liability assessment provisions of Code section 6901. This panel considers a range of third-party liability scenarios and provides insight on when the IRS pursues collection against third parties and tips for handling these cases.

Moderator: Joshua D. Smeltzer, Esq., Partner, Gray Reed, Dallas, TX

Jonathan Kalinski, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

Darren John Guillot, National Director, alliantGroup, Washington, DC

Mary E. Wood, Esq., Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX

Break | 3:30pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK I

SECURING AND DEFENDING EMPLOYEE RETENTION CREDIT CLAIMS

The period for filing Employee Retention Credit (ERC) claims closed earlier this year. With all claims in hand, the IRS is tasked with responding to each, distinguishing valid claims from invalid and abusive claims. ERC applicants and tax practitioners have seen the IRS make significant changes to ERC claim administration in recent months. The ERC voluntary disclosure program has come to a close and increasing numbers of claims are being paid. The Department of Justice is defending a growing number of claim denials (and, in some cases, unprocessed claims) in litigation, while 100’s of other claims remain pending. This panel discusses the current status of ERC refund claims and the IRS’s targeted enforcement efforts, and provides an update on refund actions and other litigation involving the ERC.

Moderator: Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA

Thomas A. Cullinan, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Atlanta, GA

Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY

Eric Hylton, National Director, alliantGroup, Washington, DC

Daniel Mayo, Esq., Partner, WithumSmith+Brown, PC, Red Bank, NJ