On January 27, 2021, Megan L. Brackney participates in a panel entitled “Representing the Promoter – Fighting on Multiple Fronts” at the ABA Virtual 2021 Midyear Tax Meeting.
Description: The IRS has ramped up its efforts to combat abusive or potentially abusive tax schemes. Enhanced coordination and collaboration is providing IRS personnel with the tools and training to identify potential promoters and refer those matters to the Lead Development Center for further case development and, if warranted, authorization of a promoter investigation under IRC 6700 or 6701. Matters may also be referred simultaneously to the Tax Division for civil injunctive action and/or to IRS-Criminal Investigation. In the midst of these parallel proceedings, promoters may find themselves the subject of invasive Congressional inquiries. Individuals and entities caught in this web are battling on multiple fronts and frequently dealing with government agencies pursuing different objectives and seeking divergent resolutions. Our expert panelists will discuss navigating these dangerous waters, avoiding conflicts, best practices for protecting privileges, responding to multiple requests for documents and information, managing public perception, challenging civil penalties, defending criminal allegations, and more.
Megan L. Brackney, Kostelanetz & Fink, LLP
Jenny Johnson Ware, McDermott Will & Emery, LLP
Brendan O’Dell, IRS Promoter Investigations Coordinator
Nanette Davis, Senior Litigation Counsel, Tax Division, US Department of Justice
Carolyn Schenck, National Fraud Counsel, Office of Chief Counsel, Internal Revenue Service
Click here for more information and to register.