June 4, 2019 - Registration begins at 1:00 PM.

2:00 - 5:50 PM (Wine and Cheese Reception from 6:00 to 7:30)

Bootcamp (Representation):

Trust Fund Payroll Issues, Criminal and Civil (Tom Rhodus, Richard Christian)   As tax professionals, we need to be able to advise our clients with employees when they do not pay their payroll taxes.   The first part of the presentation will cover the basics of the Trust Fund Recovery Penalty, both IRC 6672 and 7202.  They will include:

  • What is the Trust Fund Recovery Penalty - Explain what a trust fund recovery penalty is including talking about responsibility and willfulness. Cover the background of the 5th circuit and how a president is almost always held liable. How is the penalty computed and assessed?
  • Cover some cases that can be used as a defense and talk about how he defends against a TFRP.  For instance, how would he defend:   
    • A wife who is under the husband’s direction but he has made her an officer and routinely gives checks for her to sign.
    •  The treasurer who signs the checks but gives them to the president and the president decides who will be paid.
    •  An out of business corporation where the officers are both pointing fingers at the other one.
    • Talk about 7202 and what is the criteria is for that statute. How does IRS determine whether to go for 7202 or 6672?  What steps he would take protect his client prior to indictment?

The Taxpayer Interview:  Richard Christian and Tom Rhodus will demonstrate via mock interviews various examples of cases we might see in real life.  After each skit, they will have a substantive discussion, then skit, then discussion to include:

  •        How cases get to them, what priority do they have, goals of RO
  •      Explain how they handle investigations (Form 4180 and why the IRS wants it). 
  •        Also explain the criteria IRS has for an in-business installment agreement when the taxpayer owes taxes, and when they are requesting an installment agreement.
  •     Common scenarios related to 4180 (refusal to do 4180, agree to liability in lieu of 4180)
  •        Summons for 4180
  •     Demonstration with the Revenue Officer and representative who take opposite sides of the argument on whether or not we should allow our client to have a Form 4180 interview. Also, how do we tell if the RO is going for 7202 rather than 6672. 
  •       Discuss how a Form 4180 interview could be considered a confession in a 7202 case.  Also, discuss whether or not a Revenue Officer could be gathering information for CI in a 7202 case but only talk about 6672 to the representative.

CI Comes A Callin' (Tom Rhodus & CI Special Agent) -  There will be discussions regarding Criminal Investigation's determination whether to accept a referral for criminal prosecution when a taxpayer fails to deposit payroll taxes.  They will discuss what the speak agent is looking for and what the practitioners can do to limit criminal exposure. 

Panel Discussion (Larry Jones, Tom Rhodus, Richard Christian, Criminal Investigation Special Agent ) The panel will address the representative's tough spot when a corporation owes payroll taxes, wants an installment agreement but does not want to complete an IRS interview.  They will also discuss a series of hypothetical scenarios as well as answering attendees questions. 

Bootcamp (Preparation/Substantiation):

The Unique Tax Issues Facing Clergy, Churches and Ministries (Kathy Mannering, EA) - This topic will include preparation of an Ordained Minister's tax return who has a salary and housing allowance.  Kathy will also touch on key legal challenges to the clergy housing allowance that is currently in the courts.  

How To Fix A Broken Business Entity (John Bovard, CPA) - Sometimes our clients present a business or personal issue but when you begin preparing the return, you find out that the client's understanding is incorrect and the entity has been treated incorrectly.  John will walk us through several scenarios with steps that can be taken to "fix" the problems.  John will also address how we can protect ourselves from future misunderstandings. 

Selling and Gifting the Closely-held Business  (Dan Baucum) - A lively discussion of 5 common issues to look out for in selling and gifting ownership in a closely-held business to family or unrelated buyers. 

Wednesday, June 5, 2019 - 8:00 AM - 5:05 PM (Registration begins at 7:00 AM)

Recent Developments in Federal Income Taxation (Bruce McGovern) - This session will review the most significant developments in federal income taxation during the last twelve months that affect individuals, corporations, partnerships, and tax-exempt organizations. 

The Tax Court and The Life of A Tax Court Case (The Honorable Elizabeth Copeland) - This presentation will discuss the history of the Untied States Tax Court and what happens once a taxpayer files a petition with the Court to review and decide their tax issue. 

Dealing With Individuals With Foreign Tax Issues (Marc Enzi) - Handling common tax situations involving people from foreign countries and will include frequently asked questions about international individual tax matters. 

Addressing Conflict of Interest In Today's Practice? (Panel: Moderated by Caroline Ciraola, including John Bovard, Audrey Morris, Jeanette Ingram and Steve Carter) Tax practices are fertile ground for conflicts of interest. Whether you are representing a married couple, business partners, related organizations, vendors and clients, responsible persons, or any client who may have a conflict with a former client, it is critical that you identify potential and actual conflicts of interest at the outset of an engagement and that you continue to monitor the situation throughout your representation. Failure to properly navigate these complex and often troubled waters can pose enormous risks to tax professionals and their firms, including disqualification, disgorgement of fees, loss of clients, damage to reputation and professional discipline. This panel will discuss the ethical rules of the road for accountants and attorneys and steps each firm should take to establish a culture of compliance.

Blockchain, Bitcoin and Cryptocurrency - Taxation and Regulation (Jason Freeman) - This presentation will provide a user-friendly overview of blockchain technology and cryptocurrencies.  Attendees will learn how the technology impacts accountants, tax professionals, and their clients and will learn about important tax and other regulatory issues.  Learning Objectives:  1) Gain an understanding of blockchain technology.  2) Learn the relevant federal tax principles and rules.  3) Learn to identify relevant reporting and regulatory issues. 

When Apples Don’t Equal Apples: Divorce, Division of Marital Assets, and Tax Consequences (Michelle May O'Neil) - Discussion of Texas marital property law and the role that tax consequences play in the division of assets upon divorce. 

June 6, 2019 - (8:00 AM to 4:05 PM)

The Tribulations of Case Advocacy: The problems Taxpayer Advocate Service (TAS) encounters while being the voice of the taxpayer at the IRS.  (Rhonda Kirby) - The objective will be to describe TAS, overall, and provides real world examples of how we utilize our local offices and systemic advocacy to successfully advocate for TPs facing tax controversies.  

Ethics and the Obligation to Report Tax Evasion* (Frank Agostino) - This program will discuss the various ethical obligations faced by practitioners and judges to report tax evasion when presented to them.  The program will discuss the specific ethical rules and New Jersey's Sheridan Rule, and the obligations thereunder.

Examination Updates to International Penalties and Forms (Frank Agostino) - This program will discuss current IRS enforcement areas related to International Reporting and the penalties that may result.  Topics will include updates and strategies for practitioners representing clients in international examinations. 

Choice of Entity Considerations After Tax Reform (Clint Davis) -  Certain entities may now have a built-in advantage compared to other entities after the Tax Cuts and Jobs Act.  Explore tax saving ideas and hybrid structures to address multiple tax issues.

Section 199(A) - Qualified Business Income Deduction (Pat Sykes) -  The Tax Cut and Jobs Act of 2017 ushered in major tax changes for taxpayers. Section 199(A) also known as the “Qualified Business Income Deduction or 20% Pass-Through,” offers qualifying taxpayers a valuable reduction to taxable income. As with any tax reform, the amount of the new income reduction is contingent on several things – taxable income; type of business – specified or non- specified; QBI - qualified business income; wages paid; and UBIA-unadjusted basis of business assets.

Join us as we take a look at how it worked in 2018, talk about the impact for the taxpayer, and possible strategies going forward.

"I.  O. U." IRS (Patti Logan) - Even when a tax practitioner doesn't normally work collection cases, occasionally a client ends up owing the IRS so we need to know what to do.  This topic will cover some tips and tricks we may use to help our clients with a workable solution to the taxes they owe.  

IRS Enforcement Update:  Current State of IRS Audits and Investigations (Josh Ungerman) -  Josh will review hot topics in IRS enforcement.  Despite or because of IRS budget cuts, they are working cases more thoroughly.  Josh will focus on the current IRS practices in examination, criminal investigation, appeals and collection.  

*Qualifies as Ethics CPE for EAs

Tax Alliance Conference

Learning Objectives:  To further the attendees knowledge of Federal taxation and practice and procedures before the Internal Revenue Service.

​No prerequisites required.   Intermediate level education.


Please note that topics and schedules are subject to change.  Check back for new topics.