Seminar Number

7388

 

Early
Registration Fee:

$160

On-Site
Registration Fee:

$180

CLE Hours

6 CLE Hours
including
1 Ethics Hour and 3 Trial
Practice Hours

CIVIL AND CRIMINAL IRS TAX FRAUD INITIATIVES - Pointers and Perils for Tax Practitioners and their Clients

APRIL 29, 2010

State Bar of Georgia Headquarters
104 Marietta St., NW
Atlanta, GA

Co-Sponsor:
Taxation Law Section, State Bar of Georgia

Presiding:
Vivian D. Hoard, Program Co-Chair, Taylor English Duma, LLP, Atlanta
Sheldon M. Kay, Program Co-Chair, Sutherland Asbill & Brennan, Atlanta
7:45

REGISTRATION and continental breakfast (All attendees must check in upon arrival.  A removable jacket or sweater is recommended.)
8:25

welcome and program overview
Vivian D. Hoard
Sheldon M. Kay
8:30

Standards of Conduct for Tax Practitioners—an overview of OPR newly implemented case processing procedures, relevant sections of Circular 230 and recent developments in final agency decisions
Karen L. Hawkins, Director, Office of Professional Responsibility, IRS, Washington, DC
9:45

Offshore Compliance Initiatives and
civil fraud
Phoebe L. Nearing, Deputy Area Counsel, Small Business Self Employed Division, IRS, Jacksonville, FL
10:30

BREAK
10:45

Offshore Tax Investigations and Current Criminal Tax Investigation Initiatives including employment tax cases and FBAR proceedings
Stephen J. Waller, Area Counsel, Criminal Tax Division, IRS, Atlanta
11:45

parallel civil/criminal investigations of Abusive Tax Avoidance Transactions
Phoebe L. Nearing
Stephen J. Waller
12:15
 Lunch (Included in registration fee)
12:45

Corporate Cheating
Clint M. Fried, Associate Area Counsel, Large & Mid-Size Business Division, IRS, Atlanta
1:45

BREAK
2:00
 Representing the Target of a Criminal Investigation: Try to Keep it Civil (Until the Justice Department refers the case for prosecution—it really is a tax controversy)
Vivian D. Hoard
2:45

Things that Can Trip you up: Why is that Special Agent Here?
Joseph M. DePew, Sutherland Asbill & Brennan, Atlanta
3:30
 ADJOURN