An Introduction to Federal Tax Controversies: Audit through Litigation

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Course Information

Time 60 Minutes
Difficulty Beginner
Categories Tax Law

Course Description

Despite its reputation as one of the world’s most complex bureaucracies, the IRS must comply with certain procedural rules and afford every taxpayer the right to dispute an IRS determination. It is possible to fight the IRS if you know what to expect and are familiar with the rules of the game. During this program, Richard Nessler of Winston & Strawn LLP will explore the stages of a typical tax controversy from examination through litigation. This program will cover the IRS audit process, including IRS document requests, administrative summonses, summons enforcement and maintaining privilege. Mr. Nessler will also explore the IRS Appeals process, collection alternatives, as well as tax litigation procedures unique to the United States Tax Court, and tax refund litigation in the U.S. District Courts and U.S. Court of Federal Claims.

Learning Objectives:

  1. Provide a fundamental overview of practice before the IRS and procedures involved in tax controversies at the administrative level through civil court litigation
  2. Examine the taxpayer’s obligation to maintain records and burden of proof
  3. Review rules of tax procedure related to IRS fact gathering and ways to protect privileged communications
  4. Explain the role of an IRS Appeals Officer and the new IRS Appeals procedures
  5. Explore the importance of venue selection in choosing the proper court to decide your federal tax dispute

Credit Information

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Richard A. Nessler

Winston & Strawn LLP

Richard Nessler is of Counsel at Winston & Strawn LLP.  He is an experienced tax controversy litigator with 20 years of experience representing multinational corporations and individuals in a broad array of complex federal tax controversy matters and internal and governmental investigations.  His practice also includes the representation of clients in New York State tax controversy matters, as well as white collar investigations and related tax and appellate matters. 

He is a frequent lecturer and writer on tax controversy and litigation issues and is a contributing editor for Winston & Strawn’s tax controversy newsletter.  He also served as a Director of the New York University School of Law tax clinic and is a former law clerk to Honorable Joseph W. Bellacosa, Senior Associate Judge of the New York Court of Appeals.