Excerpt taken from the article.
This outline was prepared by Jaime Vasquez and Zhanna A. Ziering for a CLE panel that included Judge Peter J. Panuthos, Chief Special Trial Judge, of the United States Tax Court and Kevin G. Gillin from the IRS Office of Chief Counsel. The outline was drafted to provide background information regarding panel discussion topics for a seminar sponsored by the ABA Section of Taxation (2012 May Meeting).
To read the complete article, click on the above PDF.