Mark Allison Discusses Tax Controversy and Tax Litigation at NYU 77th Institute on Federal Taxation

Tips from the tax trenches from leading tax controversy practitioners in an open discussion regarding pending IRS enforcement priorities, initiatives and campaigns, including the expected termination of the IRS OVDP Procedures re FBARs, effectively responding to IRS information document requests in the new enforcement environment, hot topics and enforcement priorities within the IRS Small Business and Self-Employed Division and the IRS Large Business and International Division; recent developments regarding IRS Appeals procedures and resolution strategies; criminal tax enforcement update (foreign and domestic voluntary disclosures), current developments in the United States Tax Court; protecting privileged communications; penalty abatement considerations, and recent cases of significance.