71^st Annual

Taxation Conference: Day 2 - Focus on Tax Controversy

Thursday: Focus on Tax Controversy

Austin Dec 14, 2023 AT&T Conference Center
Conference Concluded

Live Webcast Dec 14, 2023
Conference Concluded

Buy

Related products: eConference Materials

EVENT SPONSORS
ABIP, P.C.
Clark Hill, PLC

CONFERENCE SPONSORS
Martens, Todd, & Leonard
McDonald & Adkins, LLP
Porter Hedges LLP

SUPPORTER SPONSORS
Gray Reed & McGraw LLP
McCarter & English, LLP

Download Brochure (PDF)

Overview

UT Law CLE’s 71st Annual Taxation Conference presents the expertise and in-depth analysis essential to understanding where tax law is, where it came from, and where it is going. With a renowned slate of regional and national speakers, the conference is a must attend event for those looking to keep current amidst a dramatically changing tax landscape.

We're continuing the 2-day agenda format from last year! The topics will be grouped according to the subject matter and each day will have a cohesive theme. Join us on Wednesday: Focus on Business Planning and/or Thursday: Focus on Tax Controversy.

Continue Friday with Professor Stanley M. Johanson’s popular Estate Planning Workshop offering lively discussion, practical advice, and updates.

Event Schedule

Program is subject to change.
All times are Central Time Zone.

Time

Credit

Subject

Speaker
Thursday Morning, Dec. 14, 2023
Presiding Officer:
Catherine C. Scheid, Attorney at Law - Houston, TX
7:30 am
Austin Only

Registration Opens

Includes continental breakfast.
8:20 am

Welcoming Remarks
8:30 am

2.00 hrs

Recent Developments

Review significant court decisions, rulings, and statutory and regulatory developments of the past year.

Bruce A. McGovern, South Texas College of Law Houston - Houston, TX
10:30 am

15-Minute Break
10:45 am

1.00 hr

Texas Tax Disputes: Four Ways to Get Your Ticket to the Courthouse/SALT Update

Whether you’re challenging the Comptroller’s audit assessment or denial of your refund claim, more options are available, including one that does not require paying upfront. Hear an explanation of the different ways and the advantages and disadvantages of each, insight into tax law changes from the 2023 Legislature, and more.

Jimmy Martens, Martens, Todd, & Leonard - Austin, TX
11:45 am
Austin Only

Pick Up Lunch (in Austin)

Included in registration.
Thursday Afternoon, Dec. 14, 2023
Presiding Officer:
Christina A. Mondrik, Mondrik & Associates - Austin, TX
LUNCHEON PRESENTATION
12:15 pm

1.00 hr ethics

The Government's Crackdown on Tax Fraud Enablers: How Tax Professionals Can Avoid Becoming Criminal Defendants

Tax professionals are increasingly finding themselves in very uncomfortable positions, as targets and co-defendants in criminal investigations. Hear valuable information from a former FBI agent and federal prosecutor on how tax professionals can stay out of the government’s crosshairs.

Tony Box, Gray Reed & McGraw LLP - Dallas, TX
1:15 pm

15-Minute Break
1:30 pm

1.50 hrs

IRS Operations: Looking Back and Looking Ahead

The Inflation Reduction Act of 2022 appropriated almost $80 billion to the IRS to be expended over 10 years, mostly for Taxpayer Services, Enforcement, Operations Support, and Business Systems Modernization. The speakers discuss the importance of these funds to support meaningful, effective tax administration for your clients, you, and our country.

Charles P. Rettig, Former IRS Commissioner - Los Angeles, CA
Michael J. Desmond, Former IRS Chief Counsel, Gibson, Dunn & Crutcher LLP - Los Angeles, CA
Tom Cullinan, Former IRS Counselor to the Commissioner, Chamberlain Hrdlicka - Atlanta, GA
3:00 pm

15-Minute Break
3:15 pm

1.00 hr

Effect of the APA on IRS Guidance

Taxpayers are increasingly challenging the validity of Treasury Regulations and Notices under the Administrative Procedure Act (APA). The IRS has traditionally relied on the Anti-Injunction Act as a barrier to pre-enforcement challenges to its rules and regulations, but courts are now finding APA challenges outside the scope of the Anti-Injunction Act's limitation on judicial review. Hear a discussion of current law on APA challenges to IRS guidance, as well as where the law should move.

Kristin E. Hickman, University of Minnesota Law School - Minneapolis, MN
Calvin H. Johnson, The University of Texas School of Law - Austin, TX
Susan C. Morse, The University of Texas School of Law - Austin, TX
4:15 pm

1.00 hr

Penalty Abatement Strategies That Work

With the IRS increasingly assessing penalties and viewing penalties as a source of revenue, what practical strategies work to get the IRS to abate penalties? How can I optimize the chances to get my client’s penalties abated? How does the Independent Office of Appeals analyze and resolve penalty cases? Hear the answers to those questions and more.

Dan Price, Law Offices of Daniel N. Price, PLLC - San Antonio, TX
5:15 pm

Adjourn

Download Schedule

Conference Faculty

Tony Box

Gray Reed & McGraw LLP
Dallas, TX

Tom Cullinan

Former IRS Counselor to the Commissioner, Chamberlain Hrdlicka
Atlanta, GA

Michael J. Desmond

Former IRS Chief Counsel, Gibson, Dunn & Crutcher LLP
Los Angeles, CA

Kristin E. Hickman

University of Minnesota Law School
Minneapolis, MN

Calvin H. Johnson

The University of Texas School of Law
Austin, TX

Jimmy Martens

Martens, Todd, & Leonard
Austin, TX

Bruce A. McGovern

South Texas College of Law Houston
Houston, TX

Susan C. Morse

The University of Texas School of Law
Austin, TX

Dan Price

Law Offices of Daniel N. Price, PLLC
San Antonio, TX

Charles P. Rettig

Former IRS Commissioner
Los Angeles, CA

Planning Committee

T. Charles Parr III—Chair

ABIP, P.C.
San Antonio, TX

Maxine Aaronson—Vice-Chair

Attorney at Law
Dallas, TX

R. Gordon Appleman

Holland & Knight LLP
Fort Worth, TX

Craig M. Bergez

Porter Hedges LLP
Houston, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Barbara Spudis de Marigny

Baker Botts
Houston, TX

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Lawrence B. Gibbs

Miller & Chevalier
Washington, DC

Christopher Hanna

Southern Methodist University Dedman School of Law
Dallas, TX

Donald O. Jansen

The University of Texas System
Austin, TX

Calvin H. Johnson

The University of Texas School of Law
Austin, TX

Jimmy Martens

Martens, Todd, & Leonard
Austin, TX

Kenton E. McDonald

McDonald & Adkins, LLP
Corpus Christi, TX

Lee Meyercord

Holland & Knight
Dallas, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Patrick L. O'Daniel

Norton Rose Fulbright
Austin, TX

Robert D. Probasco

Texas A&M University School of Law
Fort Worth, TX

Dawn Rhea

Weaver and Tidwell, LLP
Austin, TX

Catherine C. Scheid

Attorney at Law
Houston, TX

MCLE Credit

Texas – 7.50 hrs | 1.00 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, Tax Law

You may claim your credit online in Your Briefcase, and UT Law CLE will report credit on your behalf to the State Bar of Texas. A Certificate of Attendance will be provided in Your Briefcase for your records. The system reports Texas CLE credit every Tuesday. If you are claiming credit in the last week of your birth month, self-report your CLE credit directly to the State Bar of Texas at texasbar.com, using the course number provided on your certificate of attendance.

California – 7.50 hrs | 1.00 hrs Ethics

You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE is required to provide the State Bar with electronic attendance records for any MCLE participatory activity within 60 days of completion of the activity. The California licensee is responsible for reporting their compliance/credit hours earned to the State Bar at the end of their reporting period directly to the State Bar of California at calbar.ca.gov. UT Law CLE will maintain Attendance Records for four years.

Oklahoma – 9.00 hrs | 1.00 hrs Ethics

You must claim and certify your credit online in Your Briefcase, then you will then be provided a Certificate of Attendance for your records. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the conference.

Pennsylvania – 7.50 hrs | 1.00 hrs Ethics

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. Attorney attendance will be reported to Pennsylvania within 2 weeks after credit is claimed and submit. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact us at accreditation@utcle.org if you have additional questions.

Other States – 7.50 hrs | 1.00 hrs Ethics

Note on Self-Reporting Your Credits in Another State

If you wish to satisfy MCLE or other professional education requirements in another state for a program offered by the University of Texas School of Law, please check with the state bar or other licensing authority in that state to ensure it will qualify for self-reporting your credits.

You must claim and certify your credit online in Your Briefcase, you will then be provided a Certificate of Attendance for your records and to provided to other licensing authorities as needed.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

Certified Financial Planner (CFP) – 9.00 hrs

This course has been approved for Certified Financial Planner (CFP) credit. UT Law CLE will report your credit for you, but we do require that you claim the credit in your Briefcase and ensure your CFP number is add in your account. Contact us at accreditation@utcle.org if you have additional questions.

You can learn more at: http://www.cfp.net/

National Accounting CPE – 9.00 hrs

The University of Texas School of Law is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Delivery Method: Group-Live (UT Law CLE is a provider of NASBA Group-Live credit only, which excludes online offerings. If you need Accounting credit in any state other than Texas, please review the self-reporting guidelines on the NASBA website to confirm your ability to self-report credit from the live webcast.)

To comply with NASBA Standards, attendees claiming CPE credit must sign in to verify attendance for each segment. Attendance sign-in sheets will be available at the registration desk. You will need your CPA license number to sign in. A CPE Certificate of Completion will be provided at the conclusion of the conference.

Reporting: CPAs are responsible for reporting CPE credits earned to their state's accountancy board, and must retain appropriate documentation of their participation in learning activities. Visit your state’s reporting website for more information or www.nasba.org.

TX Accounting CPE – 9.00 hrs

The University of Texas School of Law (Provider #250) live conferences are presumptively approved by The Texas State Board of Public Accountancy for Texas Accounting CPE credit based on a 50-minute credit hour. Approved for general CPE credit only.

At the conference, you are welcome to sign in on the Accounting CPE Record of Attendance form at the registration desk, but we are now reporting all credit online. You will receive a Texas Accounting Certificate of Completion in Your Briefcase. Self-report your CPE credit directly to TSBPA. UT Law CLE will maintain Attendance Records for four years.

Contact us at accreditation@utcle.org if you have additional questions.

MCLE Credit

Texas – 7.50 hrs | 1.00 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, Tax Law

You may claim your credit online in Your Briefcase, and UT Law CLE will report credit on your behalf to the State Bar of Texas. A Certificate of Completion will be emailed to you upon claiming credit. The system reports Texas CLE credit every Tuesday. If you are claiming credit in the last week of your birth month, self-report your CLE credit directly to the State Bar of Texas at texasbar.com, using the course number provided on your certificate of attendance.

California – 7.50 hrs | 1.00 hrs Ethics

To claim California MCLE credit, California credit option must be selected PRIOR to viewing the live webcast. This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. Verification pop-ups will NOT display when the webcast video player is in "full screen" mode. Furthermore, the notification sound effect alerting pop-ups, will NOT play on mobile devices. We recommend viewing from a computer, as opposed to a mobile device, should MCLE credit, other than Texas, be needed. The response record is detailed on the Certificate of Completion.

You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE is required to provide the State Bar with electronic attendance records for any MCLE participatory activity within 60 days of completion of the activity. The California licensee is responsible for reporting their compliance/credit hours earned to the State Bar at the end of their reporting period directly to the State Bar of California at calbar.ca.gov. UT Law CLE will maintain Attendance Records for four years.

MCLE credit is presented based on a 60-minute credit hour.

Oklahoma – 9.00 hrs | 1.00 hrs Ethics

To claim Oklahoma MCLE credit, Oklahoma credit option must be selected PRIOR to viewing the live webcast. This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. Verification pop-ups will NOT display when the webcast video player is in "full screen" mode. Furthermore, the notification sound effect alerting pop-ups, will NOT play on mobile devices. We recommend viewing from a computer, as opposed to a mobile device, should MCLE credit, other than Texas, be needed. The response record is detailed on the Certificate of Completion.

The University of Texas School of Law (Provider #169) live webcast presentations meet the requirements and are presumptively approved by the Oklahoma Bar Association for MCLE credit based on a 50-minute credit hour. Upon claiming credit, a Certificate of Completion will be emailed to you. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the webcast.

Pennsylvania – 7.50 hrs | 1.00 hrs Ethics

To claim Pennsylvania MCLE credit, Pennsylvania credit option must be selected PRIOR to viewing the live webcast. This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. Verification pop-ups will NOT display when the webcast video player is in "full screen" mode. Furthermore, the notification sound effect alerting pop-ups, will NOT play on mobile devices. We recommend viewing from a computer, as opposed to a mobile device, should MCLE credit, other than Texas, be needed. The response record is detailed on the Certificate of Completion.

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. Attorney attendance will be reported to Pennsylvania within 2 weeks after credit is claimed and submitted. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact us at accreditation@utcle.org if you have additional questions.

MCLE credit is presented based on a 60-minute credit hour.

Other States – 9.50 hrs | 1.00 hrs Ethics

Note on Self-Reporting Your Credits in Another State

To claim Other States MCLE credit, Other States credit option must be selected PRIOR to viewing the live webcast. You must claim and certify your credit online in Your Briefcase, you will then be provided a Certificate of Attendance for your records and to provide to other licensing authorities as needed.

This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

Certified Financial Planner (CFP) – 9.00 hrs

This course has been approved for Certified Financial Planner (CFP) credit. UT Law CLE will report your credit for you, but we do require that you claim the credit in your Briefcase and ensure your CFP number is add in your account.Contact us at accreditation@utcle.org if you have additional questions.

You can learn more at: http://www.cfp.net/

TX Accounting CPE – 9.00 hrs

The University of Texas School of Law (Provider #250) live webcast presentations meet the requirements and are presumptively approved by the Texas State Board of Public Accountancy for Texas Accounting CPE credit based on a 50-minute credit hour. Approved for general CPE credit only.

This accreditation requires attendance verification. In compliance with the rules, UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

To claim Texas Accounting CPE credit, the Texas Accounting CPE credit option must be selected PRIOR to viewing the live webcast. Upon claiming credit, a Certificate of Completion will be emailed to you. Self-report your CPE credit directly to the Texas State Board of Public Accountancy.

Contact us at accreditation@utcle.org if you have additional questions.

Key Dates

Austin – Dec 14, 2023 – AT&T Conference Center

Conference Concluded

Live Webcast – Dec 14, 2023

Conference Concluded

Buy

Austin
Live Webcast

Individual
Last day for $350.00 Regular pricing: Nov 29, 2023

$450.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $315.00 Regular pricing: Nov 29, 2023

$415.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $280.00 Regular pricing: Nov 29, 2023

$380.00 for registrations received after this time

Last day for cancellation (full refund): Dec 6, 2023

$50 processing fee applied after this date

Last day for cancellation: Dec 8, 2023

Individual
Last day for $350.00 Regular pricing: Nov 29, 2023

$450.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $315.00 Regular pricing: Nov 29, 2023

$415.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $280.00 Regular pricing: Nov 29, 2023

$380.00 for registrations received after this time

Venue

AT&T Conference Center

The University of Texas at Austin
1900 University Avenue
Austin, TX
877.744.8822 (reservations)
Map

Accommodations

$199 room rate good through November 12, 2023 (subject to availability). Please follow this link to book your reservation online.

Parking Information

Parking is available in the hotel's attached garage, as well as Rowling Hall Garage. Both garage entrances are located on W 20th St. Guests may self-park or use the hotel's valet services at the University Avenue entrance. Parking charges are subject to changes without notification.

Self-parking fees:

Hourly Parking:

0-30 minutes, $3
31-60 minutes, $4
1– 2 hours, $6
2– 3 hours, $9
3– 4 hours, $12
4– 5 hours, $15
5– 8 hours, $18
8– 24 hours, $21

Overnight Guests:

Hotel guests may obtain a parking card at the front desk for $21 per night.

Valet Parking Rates:

Daily valet: $21

Overnight valet: $35

Our Sponsors

Thank you to our sponsors! Click each logo below to learn more.

ABIP, P.C.

ABIP is a Texas-based CPA and advisory firm with offices in San Antonio and Houston. ABIP’s client service approach is to seek and assist with value contributions as organizations grow. This approach is collaborative and technical to achieve the desired and unique goals of each client.

While each client has different needs, ABIP’s services help clients focus on their core business. The available services are robust and include access to an international network of member firms. Their clients include privately held businesses, family legacy offices, start-up companies, high-net-worth individuals, non-profits, and government entities. To learn more, please reach us at 210.341.2581.
www.abipcpa.com
Clark Hill, PLC

Clark Hill is a full service international law firm with 27 offices in the United States, Ireland, and Mexico. In Texas, Clark Hill has offices in Austin, Beaumont, Collin County, Dallas, Houston, and San Antonio. While Clark Hill is full service, it has a significant practice in tax and estate planning. To establish its presence in Texas, Clark Hill merged with the Strasburger firm in 2018, which seven years earlier had merged with Oppenheimer, Blend, Harrison and Tate, a San Antonio firm with a strong presence in tax and estate planning. Clark Hill is pleased to be a sponsor of the University of Texas Annual Tax program.
www.clarkhill.com
Martens, Todd, & Leonard

Martens, Todd & Leonard focuses its law practice exclusively on challenging audit assessments and refund claim denials pertaining to the Texas sales tax, Texas franchise tax and other Texas taxes. Martens, Todd & Leonard works with clients during audits, and undertakes challenges at administrative hearings, in the state trial and appellate courts, as well as in the Texas supreme court.

We have successfully tried these Texas sales tax and franchise tax cases: Combs v. Roark Amusement & Vending, L.P.; Hegar v. Gulf Copper and Manufacturing Corp.; Titan Transportation, L.P. v. Combs; Combs v. Newpark Resources, Inc.; Hegar v. CGG Veritas Services (U.S.), Inc.; Pointsmith Point-of-Purchase Management Services, L.P. v. Hegar; Garriott v. Combs; L.P.; Taylor & Hill, Inc. v. Combs.
texastaxlaw.com
McDonald & Adkins, LLP

Significant businesses throughout Texas rely on McDonald & Adkins, LLP, for experienced counsel and representation.

With over 44 years of experience, Kenton McDonald’s practice is focused on helping clients structure their businesses and transactions in a tax-advantaged manner; structure their estates to minimize estate taxes; and contest unfavorable actions proposed by the IRS.

With 30 years’ experience as a trial attorney, Alissa Adkins has a broad civil litigation practice involving contested matters in state and federal trial and appellate courts, including the U.S. Bankruptcy Court.

McDonald & Adkins, LLP, has been selected by U.S. News and World Report as a top tier law firm for Tax Law.
mcdonaldadkins.com
Porter Hedges LLP

Founded in 1981, Porter Hedges is a full-service Houston-based law firm with an office in Oklahoma City. We provide the highest quality work across a range of industries, with particular preeminence in the energy sector. As leading practitioners, we are committed to excellence across our firm and favor an efficient, value-minded approach to serving our clients. We develop practical and integrated solutions to complex challenges that we approach with a business-oriented mindset.

Porter Hedges tax lawyers help businesses, exempt organizations, and individuals plan and achieve their financial objectives while maximizing their tax advantages. We integrate tax planning, transactional assistance, and tax controversy resolution in advising clients on all aspects of federal, state, local, and international taxation. Our tax lawyers regularly assist company owners and executives, chief financial officers, tax directors, bankers, outside accountants, and other advisors in creating sophisticated solutions for complex tax challenges.
www.porterhedges.com

71st Annual

Taxation Conference: Day 2 - Focus on Tax Controversy

Thursday: Focus on Tax Controversy

Austin Dec 14, 2023 AT&T Conference Center Conference Concluded

Live Webcast Dec 14, 2023 Conference Concluded

Buy

Related products: eConference Materials

Overview

Event Schedule

Thursday Morning, Dec. 14, 2023

Thursday Afternoon, Dec. 14, 2023

Conference Faculty

Tony Box

Tom Cullinan

Michael J. Desmond

Kristin E. Hickman

Calvin H. Johnson

Jimmy Martens

Bruce A. McGovern

Susan C. Morse

Dan Price

Charles P. Rettig

Planning Committee

T. Charles Parr III—Chair

Maxine Aaronson—Vice-Chair

R. Gordon Appleman

Craig M. Bergez

Michael L. Cook

Barbara Spudis de Marigny

Dennis B. Drapkin

Lawrence B. Gibbs

Christopher Hanna

Donald O. Jansen

Calvin H. Johnson

Jimmy Martens

Kenton E. McDonald

Lee Meyercord

Christina A. Mondrik

Patrick L. O'Daniel

Robert D. Probasco

Dawn Rhea

Catherine C. Scheid

Credit Info

MCLE Credit

Other Credit

MCLE Credit

Other Credit

Key Dates

Venue

AT&T Conference Center

Accommodations

$199 room rate good through November 12, 2023 (subject to availability). Please follow this link to book your reservation online.

Parking Information

Our Sponsors

Stay in the loop with UT Law CLE

71^st Annual

Austin Dec 14, 2023 AT&T Conference Center
Conference Concluded

Live Webcast Dec 14, 2023
Conference Concluded