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