Blair Hlinka Moderates Panel on Hot Topics in Refund Litigation at ABA Midyear Tax Meeting 

The panelists will explore various intermediate and advanced concepts in refund litigation. Specifically, the panelists will discuss key considerations and common pitfalls in refund litigation, including: choice of forum; the Flora full payment rule; claims for refund vs. abatements; the variance doctrine; and offsets. The panelists will also offer practical tips for handling currently trending refund litigation, including the employee retention credit (ERC), international information reporting penalties after Farhy, and challenging promoter penalties and responsible person determinations under the ERC and otherwise.