International Controversy Update - Civil and Criminal 2023
The last year saw some exciting pro-taxpayer changes in the area of international taxation controversy. This panel of IRS employees, tax professionals and attorneys explore both Farhy v. Commissioner and Bittner v. Commissioner. Also, the panel explores recent changes in at the IRS Independent Office of Appeals including their obligation to produce evidence in a 6751(b) penalty appeal and a recent policy change which denies admission of new evidence that the Service wasn’t previously provided with prior to the appeal. Finally, the panel takes a deep dive into recent developments in privilege which affects preparers, Kovel accountants, and those relying on IRC 7525 protections.
Tax Professionals that attend are encouraged to accept a pro bono tax controversy case assignment from NYCLA, an ABA-sponsored Tax Court Pro program or a NY or NJ low-income Tax Clinic.
Frank Agostino
,
Esq.
Frank Agostino is one of the most accomplished tax controversy attorneys in the country, with more than four decades of litigation experience and a string of landmark victories that have reshaped IRS enforcement and Tax Court procedure — including Commissioner v. Zuch before the U.S. Supreme Court (2025) and Chai v. Commissioner in the Second Circuit (2017).
Because of Frank’s stellar reputation in the tax bar, he has been ranked in Chambers in Band 1 for Tax: Fraud Nationwide (USA) and in Band 1 for High Net Worth Private Client: Tax.
A former IRS District Counsel attorney and Special Assistant U.S. Attorney, Frank has also taught tax controversy at Seton Hall and Rutgers Law, and currently serves on the Advisory Board of the Journal of Tax Practice and Procedure.
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