CV: PRESENTATIONS AND PUBLICATIONS

SEMINAR PRESENTATIONS

2020

July – Webinar: Post COVID Collection Process, A Panel.

2019

January: Mid-Year: Collection Due Process Litigation: An Update (A panel – 2: New Orleans)

Passport Revocation – State Department Denial or Revocation – not a panel. New Orleans

May: May Meeting – Current Enforcement Priorities in Collection (Panel, Washington)

2018

February: Mid-Year: Panelist – Collection Issues Affecting Estates, Donors, and Donees. San Diego

May: Collection Abroad – Passport Revocation and Beyond – Panel

October: Joint Meeting – Quiet Title Actions and Federal Tax Liens – The Basics and Attacking IRS Nominee and Alter Ego Liens. Atlanta.

IRS Nationwide Tax Forum: June and November – Orlando and Atlanta – Nuts and Bolts of Tax Collection and CDP Collection Issues Affecting Estates, Donors and Donees.

December: National Institute on Tax Controversy: Passport Denial and Revocation

2017

ABA Section on Taxation

  • August, 2017 IRS Nationwide Tax Forum: Tax Audits: Triggers and Tips
  • January, 2017 – Mid-Year Meeting – Quiet Title Actions – The Sword – Not the Shield. Orlando
  • May, 2017 – A Comparison: An Offer in Compromise and a Discharge in Bankruptcy – The Variables and the Processes. Washington
  • September, 2017 Joint Fall Meeting: Collection Workshop – Panel Presentation Austin
  • December: National Tax Controversy Institute: Marijuana – Ethical and Legal Issues in Representing Taxpayers. Vegas

2016

ABA Section on Taxation

  • January, 2016 – Mid-Year Meeting “Late Filed Returns”
  • May, 2016 – The IRS Future State – The Collection Functions and Enforcement
  • December, 2016 – The “Intentional” Tax Bankruptcy – Discharge and Litigation

2015

ABA Section on Taxation, Criminal and Civil Penalties Committee, Houston, TX, January 29, 2015

  • Bankruptcy: The Judicial Answer to Unpaid Federal Tax Liabilities
  • Discharge of Taxes in the Aftermath of McCoy

ABA Business Law Section, Webinar, May 19, 2015

  • Discharge of Tax Liabilities in Bankruptcy: Late Filed Returns and The Internal Revenue Service

2014

ABA Section on Taxation, Bankruptcy and Workout Committee, Phoenix, AZ, January 23, 2014

  • Dealing with State Tax Authorities in Bankruptcy: Unpaid Federal Tax Liabilities
  • The Office of Professional Responsibility the IRS Collection Process and the Bankruptcy World

Florida Bar Association, Tax Section, Orlando, FL, April 24, 2014

  • IRS APPEALS — Appeals Judicial Approach and Culture
  • IRS Compliance and Appeals Issues

ABA Section of Taxation, Bankruptcy and Workout Committee, Washington, DC, May 8, 2014

  • IRS Compliance and Appeals Issues — The Collection Perspective
  • Tax Priorities and Dischargeability: Application of Sections 507 and 503 of the Bankruptcy Code

American Law Institute, Washington, DC, October 15, 2014

  • IBankruptcy: The Judicial Answer to Unpaid Federal Tax Liabilities

Tennessee Federal Tax Conference, Brentwood, TN, November 19, 2014

  • Circular 230 and the Office of Professional Responsibility (OPR): Enforcement
  • OPR: Director’s Update

Great Plains Federal Tax Institute (Nebraska CPAs), Omaha, NE, December 4, 2014

  • A Tax Map for The Bankruptcy Process – Tax Issues Only
  • Using Bankruptcy to Provide Relief from Tax Debt

ABA Criminal Tax Controversy Institute, Las Vegas, NV, December 10, 2014

  • Closing the Audit: The Options.

2013

ABA Tax Section Mid-Year Meeting, Orlando, FL, January 25, 2013

  • The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy Protection
  • IRS Collection & Bankruptcy Alternatives
  • Tough Issues in Bankruptcy Tax and Annual Updates

ABA 2013 May Meeting, Washington, DC, May 10, 2013

  • A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice

TN Society of Certified Public Accountants, Chattanooga Tax Practitioners, Chattanooga, TN, July 12, 2013

  • The IRS Collection Process: The Taxpayer Advocate, and IRS 2012 “Fresh Start”

IRS Nationwide Tax Forum

  • Atlanta, GA
    August 20-22, 2013
  • San Diego, CA
    September 16-19, 2013

Tax Debt Relief in Bankruptcy

TSCPA – Tennessee Federal Tax Conference, Brentwood, TN, November 20-22, 2013
Two Presentations

  • The Internal Revenue Service Examination – How to Handle: Planning and Pitfalls
  • The Internal Revenue Service’s Collection Due Process “Hearing”: A
    Misnomer? Litigating the Collection Process

30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV, December 11-13, 2013

  • Dialing for Dollars: The IRS Collection Process – Administrative and Judicial Solutions

2012

ABA Section on Taxation, Bankruptcy and Workouts Committee 2012 Mid-Year Meeting, San Diego, CA, February 17, 2012 (Moderator and Prepared Materials)

  • Tax Litigation: Tax Court or Bankruptcy Court – When, Where, How and Why

ABA Section on Taxation and Bankruptcy and Workouts Committee, May 10-12, 2012 (Moderator and Prepared Materials)

  • Top Ten Hot Button Issues – Bankruptcy Tax Procedural Issues* (*and Foot Faults) (A Panel Discussion)
  • Bankruptcy, Collections and the Collection Due Process Appeal

ABA Section on Taxation and Section of Real Property, Trust and Estate Law – 2012 Joint Fall CLE Meeting, Boston, MA, September 14, 2012

  • When and How to Withdraw from Representation Consistent with the Ethics Rule

National Association of Consumer Bankruptcy Attorneys (NACBA), Amelia Island, FL, November 4-5, 2012

  • Top Ten “Hot Button” Issues* (*and Foot Faults) – Bankruptcy Tax Procedure (and a bit of Substance) (A Panel Discussion)

TSCPA – Tennessee Federal Tax Conference, Franklin, TN, November 14, 2012

  • Voluntary Disclosure: Definitions and Mechanics and the 2012 Offshore Voluntary Disclosure

ABA 29th Annual National Institute on Criminal Tax Fraud and 2nd National Institute on Tax Controversy, Las Vegas, NV, December 6-7, 2012

  • Administrative Tax Strategies and Techniques in a Recessionary Economy

2011

ABA 2011 Midyear Meeting of Closely Held Businesses and Bankruptcy & Workouts, Boca Raton, FL, January 21, 2011

  • Treatment of the Secured Tax Claim in Bankruptcy

American Institute of CPAs (AICPA), Las Vegas, NV, May 5-6, 2011

  • Unpaid Federal Tax Liabilities, The IRS Collection Process and the Bankruptcy Alternative

TSCPA – Tennessee Federal Tax Conference, Brentwood, TN, November 16-18, 2011

  • Internal Revenue Service Criminal Tax Investigations: A Primer for “Civil” Tax Advisors

2010

ABA 2010 Midyear Meeting of Closely Held Businesses and Bankruptcy & Workouts, San Antonio, TX, January 22, 2010

  • Tax and Bankruptcy Considerations When Representing Financially Distressed Entities and Their Owners

ABA Tax Section – State Bar of Wisconsin, Milwaukee, WI, March 12, 2010

  • Let’s Make a Deal with The IRS – OR – Is A Bankruptcy Discharge the Answer – Tax Implications: Workouts and Bankruptcy

TN Society of Enrolled Agents – TSEA Annual Tax Seminar, Brentwood, TN, May 20-21, 2010

  • Tax Issues in Bankruptcy

9th Annual NC/SC Tax Section, Kiawah Island, SC, May 28-30, 2010

  • Tax Issues in Bankruptcy

Maryland Association of Certified Public Accountants – Advanced Tax Institute, Baltimore, MD, November 2, 2010

  • Unpaid Federal Tax Liabilities

TN Society of Certified Public Accountants (TSCPA), 2010 Tennessee Federal Tax Conference, Franklin, TN, November 18, 2010
Three Presentations:

  • Bankruptcy Taxation: The Tax Life Cycle of a Business Bankruptcy
  • IRS Tax Penalties: “The Practical Approach” (A Panel Discussion)
  • Voluntary Disclosure: Correcting Errors and Eliminating Criminal Prosecution

2009

2009 IRS Nationwide Tax Forum

  • Federal Tax Treatment of Debt Workouts

Southern Federal Tax Institute, Atlanta, GA, October 19-23, 2009

  • IRS Collection Issues and The Bankruptcy Alternatives

ABA CLE Teleconference, October, 28, 2009

  • Let’s Make a Deal With the IRS – OR – Is Discharge the Answer?

Georgia Tax Forum, Savannah, GA, November 11-14, 2009

  • The IRS v. The Bankruptcy Code

Tennessee Federal Tax Conference, Brentwood, TN, November 11-18, 2009

  • IRS Collection Issues: Bankruptcy vs. IRS Administrative Options

PUBLICATIONS

Corporation Federal Tax Status – Property of the Bankruptcy Estate?, Norton’s Bankruptcy Law Adviser (July, 2013)

Collection Due Process Hearings – The Internal Revenue Manual: A Statement of Administrative Procedures?, CCH Journal of Tax Practice & Procedure (April-May, 2012)

Federal Income Taxation of the Individual Chapter 11 Debtor and the Bankruptcy Estate: Double Taxation — Really?, Norton’s Bankruptcy Law Adviser (April, 2011, Co-Author: Frances Sheehy)

The Subprime Mortgage Debacle: A Tax Issue?, Norton’s Bankruptcy Adviser (March, 2009)

The Internal Revenue Service and Tax Opinions on Litigation Hazards: Not Work Product!, Tennessee Bar Journal (March, 2008)

The Hunt for Tax Accrual Work Papers, Tennessee Bar Journal (March, 2008)

Bankruptcy Tax Issues: The Conflict of Codes!, Enrolled Agents Journal (May-June, 2002)

LECTURES/PANELS

Association of Insolvency and Restructuring Advisers

Chattanooga Tax Practitioners’ Club

Kentucky Federal Tax Institute

IRS National Tax Forums

Maryland Association of Certified Public Accountants

NYU Institute on Federal Taxation

Section on Taxation, American Bar Association

Southern Federal Tax Institute

Tennessee Federal Tax Institute

Tennessee Federal Tax Conference

Tennessee Society of Certified Public Accountants

Tennessee Society of Enrolled Agents

Wisconsin Bar Association