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Scott Michel to Speak at NYU Institute on Federal

November 11, 2012
Panelist:Scott D. Michel
Program:From the Experts: Tax Controversy and Tax Litigation Update
Event Sponsor:New York University, 71st Institute on Federal Taxation
Where:

The event will be held at the Hilton New York from October 21-26 2012 and at the Hotel Del Coronado in San Diego, California from November 11-16 2012.

The panel is an open forum discussing pending IRS enforcement initiatives, hot topics and enforcement priorities within the IRS Operating Divisions; update from IRS Appeals; criminal tax enforcement update (foreign and domestic) and current developments in tax litigation and legislation of significance.

Discussion will also include private practitioner updates re (i) ongoing IRS examinations involving previously undisclosed interests in foreign financial accounts, the current IRS Offshore Voluntary Disclosure Initiative (OVDI), and the current status of the interaction between the Required Records Doctrine and the 5th Amendment relating to records of a foreign financial account, (ii) reliance or ignorance as a possible defense to civil penalties or criminal sanctions (iii) adequate disclosure within a tax return, (iv) handling taxpayer and return preparer interviews in a sensitive issue IRS examination, (v) use of IRS Audit Technique guides and a FOIA Requests during an IRS examination, and (vi) examinations of high wealth taxpayers including a discussion of typical IRS examination inquiries.

The panel will begin at 1:15 pm on October 21 at the Hilton New York and at 1:15 pm on November 11 at the Hotel Del Coronado.