International Domestic Tax Controversy Update - 2023
International and Domestic Criminal Tax Enforcement Updates/Challenging Information Returns and Third-Party Information Reports -
An expert panel of criminal tax attorneys, current IRS criminal investigation personnel and a former CI employee take the attendees through current topics in criminal tax enforcement. These include an overview of the “J5”, a discussion on illegal income and money laundering, an update to Digital Asset and Crypto crimes; Covid frauds and the current Dirty Dozen list. After some case study presentations, the panel discusses how CI investigates crimes, and what some of the “dos and don’ts” are for tax practitioners facing involvement in a CI case.
The second part of the panel includes attorneys and CPAs involved in representing taxpayers who are faced with inaccurate 3rd part information returns, including forms 1099C, K1, W@G, 1099-MISC, 1099-nEC and forms 1099-K. Their conversation centers on how the practitioner can successfully challenge these documents in an adversarial IRS proceeding. Finally, the panel will discuss subpoena compliance by tax practitioners.
International Controversy Update – Civil and Criminal
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.
Civil & Criminal COVID Tax Controversy & Enforcement -
This panel includes representatives from the IRS Office of Fraud Enforcement, along with attorneys and CPAs from major law and accounting firms discussing recent industry issues. These issues include ERC Fraud, ERC Rules and Myths, ERC Criminal Investigations, and recent ERC matters in the news.
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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