Chair: Guinevere Moore, Johnson Moore LLC, Chicago, IL
Vice-Chair: Matthew Cooper, Deloitte Tax LLP, Washington, DC
Ethical Issues in Federal Tax Practice – The Government Perspective.
This panel will provide an update on recent guidance from the Internal Revenue Service and the Treasury Department, discuss issues of concern and areas of focus for the IRS Office of Professional Responsibility and Office of Chief Counsel, and give an update on pending cases that relate to tax practice standards.
Moderator: Aaron Esman, Caplin & Drysdale Chartered, New York, NY
Panelists: Sharyn M. Fisk, Director, IRS Office of Professional Responsibility, Washington, DC; Emily Lesniak, Special Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC
Ethical Considerations for Limited Scope Engagements.
Ethical considerations in pro bono representation, whether practicing before the IRS or before the Tax Court. Panelists will discuss dilemmas pro bono attorneys may face when representing tax clients at settlement days, calendar calls, and via direct representation outside of the courtroom. Discussions will include limited scope and limited time representation. Panelists will also provide advice on how to avoid the perils related to pro bono representation of taxpayer clients. This panel is the first part of a two part series co-sponsored with the Pro Bono Committee.
Moderators: Shanthy Balachanthiran, Florida Rural Legal Services Inc., LITC, Ft. Myers, FL
Panelists: The Honorable Peter J. Panuthos, US Tax Court, Washington, DC; Jennifer Breen, Morgan Lewis & Bockius, Washington, DC; Guinevere Moore, Johnson Moore LLC, Chicago, IL; Scott Hessell, Sperling & Slater, Chicago, IL; Jennifer Auchterlonie, Special Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC
Ethical Considerations Arising Out of the BBA Partnership Audit Rules.
Now that the BBA partnership audit regime is in full swing, interesting ethical questions are arising in both the IRS examination and partnership amended return contexts. This panel will explore practitioners’ ethical considerations relating to the broad authority of the partnership representative, the lack of participation and notice rights to all partners, the submission of administrative adjustment requests, and other novel issues under the BBA rules. In addition, this panel will discuss giving advice to partnerships and partners who may have conflicting interests as to the best way to resolve an IRS audit or correct a partnership return.
Moderator: Matt Cooper, Deloitte Tax LLP, Washington, DC
Panelists: Emily Lesniak, Special Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC (Invited); Sheri Dillon, Morgan Lewis & Bockius LLP, Washington, DC; Rochelle Hodes, Crowe LLP, Washington, DC; Alice Harbutte, EY, Denver, CO