For the last several years, the ABA Section of Taxation Pro Bono & Tax Clinics committee has organized a Low-Income Taxpayer Representation Workshop in early December in Washington, D.C. Keith, Les, and I have all been involved with the committee and the workshop at various times over the years. The workshop is a nice opportunity for practitioners interested in low-income taxpayer representation issues to come together for an afternoon of learning and conversation.
This year’s workshop will be on Monday afternoon, December 3, at the D.C. offices of Morgan, Lewis & Bockius LLP. Workshop organizer Caleb Smith has lined up four hours of CLE/CPE with exciting speakers on important topics including section 199A, tax litigation, and collection due process. While the workshop is designed for practioners who represent low-income taxpayers through a Low-Income Tax Clinic or other pro bono program, all are welcome to attend.
Registration is a bargain at $30, reflecting the Tax Section’s commitment to supporting low-income taxpayer representation, and also Morgan Lewis’s generous hosting. (Shout out also to the workshop’s longtime past host McDermott Will & Emery.)
1:00 p.m. The 2017 Tax Act and Self‐Employed Workers
This panel will discuss new code section 199A as well as tax planning issues for self‐employed and “gig economy” workers in light of the changes made by the 2017 tax act. The panel will also discuss how these changes in the tax law will be reflected during the filing season on the draft 2018 Form 1040.
Moderator: Caleb Smith, Ronald M. Mankoff Tax Clinic, University of Minnesota Law School, Minneapolis, MN
Panelists: Joseph Tiberio, IRS SB/SE, Washington, DC; Caroline Bruckner, American University Kogod School of Business, Washington, DC; Lisa Sperow, Cal Poly Low Income Taxpayer Clinic, San Luis Obispo, CA.
2:00 p.m. Collectability as a Litigation Tool: Settling with DOJ vs. IRS
This panel will discuss taxpayer collectability as a factor in litigation with the Internal Revenue Service in pre‐assessment Tax Court cases, and with the Department of Justice in post-assessment District Court litigation. The panel will discuss differences in the IRS and DOJ approaches on how to treat a taxpayer’s collection potential as a factor in settling cases.
Moderator: Tameka Lester, Georgia State University College of Law, Atlanta, GA
Panelists: Valerie Vlasenko, Agostino & Associates, Hackensack, NJ; Erin Stearns, Director, University of Denver Low Income Taxpayer Clinic, Denver, CO; Carol Koehler Ide, Assistant Chief, Civil Trial Section, Tax Division, U.S. Department of Justice; additional panelists TBA
3:30 p.m. Break (no CLE/CPE)
3:45 p.m. New Trends and Tactics in CDP Litigation
This panel will discuss emerging trends in Collection Due Process litigation, recent precedential court decisions, and identify traps for the unwary.
Moderator: Omeed Firouzi, Christine A. Brunswick Public Service Fellow, Philadelphia Legal Assistance, Philadelphia, PA
Panelists: Keith Fogg, Director Harvard Federal Tax Clinic, Jamaica Plain, MA; Tom Thomas, University of Missouri, Kansas City; Steve Milgrom, Legal Aid Society of San Diego, San Diego, CA; additional panelists TBA
5:15 p.m. Networking Reception (no CLE/CPE)