Kostelanetz LLP

41st Annual UCLA Tax Controversy Conference
2025-10-23
Kostelanetz attorneys Andrew Weiner, Bryan C. Skarlatos, and Karen Kelly will speak at the 41st Annual UCLA Tax Controversy Conference at the Beverly Hills Hotel in Los Angeles on October 23, 2025. Continuing education credit is offered, and attendance is in-person only. Kostelanetz is a proud Silver sponsor of this conference. Kostelanetz partner Caroline D. Ciraolo will also be in attendance at the conference.
Our attorneys will present the following sessions:
Thursday, Oct. 23, 2025, from 2:10 p.m. to 3:10 p.m. Pacific
“Valuation in Tax Enforcement Critical to Our Voluntary Compliance System”
Kostelanetz participant: Andy Weiner
Thursday, Oct. 23, 2025, from 3:10 p.m. to 4:10 p.m. Pacific
“Navigating IRS Resource Challenges – From the Taxpayer Advocate Service to Self-Help Options for Taxpayers and Tax Professionals”
Kostelanetz participant: Bryan Skarlatos
Thursday, Oct. 23, 2025, from 4:45 p.m. to 5:50 p.m. Pacific
“The Future Direction of Criminal Tax Enforcement”
Kostelanetz participant: Karen Kelly
You can learn more about the conference and register here.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a Forbes contributing columnist on tax controversy and tax policy and a frequent writer and speaker on tax issues. He is also a fellow of the American College of Tax Counsel.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. She was twice honored by the Department of Justice with the Attorney General Award for Outstanding Service. Her practice focuses on defending clients in state and federal criminal tax and white-collar investigations and prosecutions and representing clients in government investigations and enforcement actions. Karen draws on her extensive government experience to provide clients with insight and nuanced risk assessments and to provide a common-sense approach to best steps forward in complex criminal matters.

Access to Tax Return Information – Are We Opening the Floodgates?
2025-10-28
Caroline D. Ciraolo will present “Access to Tax Return Information – Are We Opening the Floodgates?” to the Georgetown University Law Center Tax Scholars on October 28, 2025.
Caroline will discuss the scope of the tax privacy statute, the statutory exceptions, and pending litigation involving agreements between the IRS and other government agencies share return information for immigration enforcement and other Administration priorities.
You can learn more about Caroline’s role with Georgetown University Law Center here.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Hawaii Tax Institute 2025
2025-11-04 - 2025-11-05
Caroline D. Ciraolo will join two panels at the 2025 Hawaii Tax Institute scheduled for November 2-6, 2025, at the Sheraton Waikiki Resort in Honolulu. Continuing education credit is offered for attendees, and virtual attendance options are available.
Tuesday, Nov. 4, 2025 1:30 p.m. to 2:30 p.m. HST
Exempt Organizations Under Attack: Defending Exempt Status
In this session, Caroline will join Sarah Green, senior attorney at Dentons, and Rachel Leiser Levy, principal of Deloitte Tax LLP’s Washington National Tax division and former IRS Associate Chief Counsel, Employee Benefits, Exempt Organizations and Employment Taxes, to discuss the risks that exempt organizations face in the current political environment and how practitioners can best advocate for their exempt organization clients. Topics will include the processes by which organizations obtain exempt status, IRS audit procedures for exempt organizations, established IRS procedures likely to seek revocation of exempt status, and how to challenge proposed and final revocations.
Wednesday, November 5, 2025 1:30 p.m. to 2:30 p.m. HST
Clemency, Pardons, and Commutations: Navigating the Rules, Managing Client Expectations, and Ethical Considerations
In this session, Caroline will join Sandra Brown, shareholder of Hochman Salkin Toscher Perez PC and former Acting U.S. Attorney, Central District of California, and Sharyn Fisk, associate accounting professor at Cal Poly Pomona’s College of Business Administration and former Director of the IRS Office of Professional Responsibility, to review the legal, practical, and ethical issues relevant when advising clients facing criminal investigations or dealing with prior convictions and are curious about seeking pardons.
You can learn more about the conference and register here.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes

2025 Insurance Tax Conference
2025-11-06
Melissa Wiley will present at the 50th Annual Insurance Tax Conference at the Hyatt Regency in New Orleans, LA, on November 6, 2025.
Melissa’s session, “Tax Controversy: How to Deal with the IRS in the Current Environment,” will provide attendees with insights on how to resolve their clients’ IRS issues amid reduced agency staff and shifting priorities.
You can learn more about the conference and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. An actuary by training, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

NYSSCPA Tax and Financial Planning for Individuals Conference
2025-11-06
Frank Agostino will present a session at the NYSSCPA Tax and Financial Planning for Individuals Conference on November 6, 2025, at the FAE Learning Center in New York, NY. Continuing education credit and virtual attendance options are available.
Frank’s session covers the “One Big Beautiful Bill” (OBBB) and the numerous sweeping changes for individual taxpayers. Attendees will learn about key provisions of OBBB, permanent changes including higher standard deductions, temporary tax benefits like the exclusion of tip income, and the above-the-line auto loan interest deduction. Frank will discuss tax planning opportunities arising from OBBB, like the revised SALT cap and comparisons of the tax benefits of the QBI deduction and tax-free capital gains from §1202 stock.
Frank will be joined by Walter Primoff, director of Perelson Weiner LLP.
You can learn more about the conference and register here.
About Frank
During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.

2025 Art Law Day: What’s the (Tax) Value of Art?
2025-11-07
Melissa Wiley will present a session titled “What’s the (Tax) Value of Art?” at the Appraisers’ Association of America’s (AAA) 2025 Art Law Day on November 7, 2025. The event will be held at the AAA’s New York City headquarters in Midtown Manhattan from 9:30 a.m. to 10:45 a.m. Eastern. Continuing education credits and virtual attendance options are available; however, credits are only awarded for in-person attendance.
Melissa’s session delves into the tax impact of art donations for both donors and tax-exempt organizations. Topics include how to substantiate art donations, reporting charitable contributions of art, common IRS challenges, and the risks that donors and tax-exempt organizations face. The session will be moderated by Meghan Biss of Loeb & Loeb LLP, and Melissa will be joined by fellow panelists Karin Gross of K. Tyson Law PLLC and Kristina Rasmussen of Deloitte Tax LLP.
You can learn more about Art Law Day and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

University of Chicago Law School Federal Tax Conference 2025
2025-11-07
Caroline D. Ciraolo will participate as a panelist in a session titled “Is Section 6103 Providing The Protections It Promised? And Should It?” at the University of Chicago Law School’s 78th Annual Federal Tax Conference on Friday, November 7, 2025, from 10:20 a.m. to 11:50 a.m. Central at the Gleacher Center.
The panel will be moderated by John Hildy, partner, Mayer Brown LLP, and will include a presentation by Joseph Thorndike, Contributing Editor, Tax Notes and Director, Tax History Project at Tax Analysts, regarding the historical context of Section 6103. Following the presentation, the panelists, including Caroline and Michael Desmond, member, Miller & Chevalier, and former IRS Chief Counsel, will engage in a discussion regarding the scope of Section 6103, the application and limitations of the many statutory exceptions, and current scrutiny in light of agreements between the IRS and other federal agencies to support the Administration’s enforcement priorities.
You can learn more about the conference and register here.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

White Collar Support Group™ Tuesday Speaker Series: A Panel on Restitution & Forfeiture, presented by the Women’s White Collar Defense Association (WWCDA)
2025-11-11 19:00 - 20:00 (America/New_York)
Caroline D. Ciraolo will join fellow members of the Women’s White Collar Defense Association (WWCDA) to present a panel on “Restitution and Forfeiture” to the White Collar Support Group Tuesday Speakers Series. The webinar will take place November 11, 2025, from 7 p.m. to 8 p.m. Eastern.
The discussion will cover the fundamentals of restitution and forfeiture orders. Attendees will learn the differences between forfeiture and restitution, how the two concepts converge, types of assets subject to forfeiture and restitution, unique IRS issues related to restitution and corresponding civil tax liabilities, and how to limit potential exposure during white-collar criminal proceedings.
Caroline will be joined by Margaret Graham and Jillian Berman, former Department of Justice prosecutors who represented individuals and entities in government investigations and criminal and regulatory matters. They will share their insights on forfeiture and restitution in federal criminal matters and how practitioners can strategize their defenses considering recent DOJ practices.
The White Collar Support Group™ is a community of individuals, families, and groups who have been impacted by the criminal justice system. Over the past ten years, over 1,650 members have participated in over 490 weekly support group meetings from every state in the country – and Canada, the U.K., South America, Central America, Israel, Mexico, Europe, Scandinavia, and the Caribbean. The WCSG provides peer and mentoring support, white-collar job and career connections, relevant news and events, advocacy initiatives, partnerships with other nonprofits, and a wide array of other resources.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Mental Health Issues in Tax Practice
2025-11-12 - 2025-11-14
Melissa Wiley will present a program titled “Mental Health Issues in Tax Practice” at the 2025 California All-Tax Conference hosted by the California Lawyers Association. The conference will be held at the Westin San Diego Bayview, November 12-14, 2025. Continuing education credit is available.
Melissa’s session takes place on Thursday, November 13, from 2:25 p.m. to 3:15 p.m. This session will cover how clients’ mental health struggles may affect their tax cases. Mental health issues can hide in plain sight, and practitioners often don’t think to ask about how their clients are doing mentally or consider how mental health issues may impact their case.
You can learn more about the conference and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

84th Institute on Federal Taxation (San Francisco)
2025-11-16 - 2025-11-21
Kostelanetz attorneys Andrew Weiner and Bryan C. Skarlatos will speak at the 84th Institute on Federal Taxation, hosted by the NYU School of Professional Studies. The conference will be held in San Francisco at Fairmont Hotel from November. 16-21, 2025.
Andrew’s session, “Nuts and Bolts of a Partnership BBA Audit,” will take place on November 19th at 1:45 p.m. Pacific. He will be joined by Mary I. Slonina of KPMG.
Bryan’s session, “The Role of the Tax Advisor in the Tax System: Ethical and Penalty Standards for Advising Clients,” will take place on November 21st at 5:15 p.m. EST. He will be joined by Michael R. Stein of Hochman Salkin Toscher Perez P.C. and G. Michelle Ferreira of Greenberg Traurig.
The Institute on Federal Taxation is a six-day conference that offers practitioners the opportunity to earn over 40 hours of continuing education credits in a plethora of complex tax law topics. Session topics will include current developments in tax controversy, international taxation issues, trusts and estates, executive compensation and employee benefits, practice ethics, and more.
You can learn more about the conference and register here.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a Forbes contributing columnist on tax controversy and tax policy and a frequent writer and speaker on tax issues. He is also a fellow of the American College of Tax Counsel.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.

AICPA National Tax Conference
2025-11-17 - 2025-11-18
Melissa Wiley will present two programs at the 50th AICPA & CIMA National Tax Conference taking place at the Washington Hilton in Washington, D.C., on November 17-18, 2025. Melissa is also a member of the planning committee for the AICPA National Tax Conference.
Continuing education credits and virtual attendance options are available.
Monday, November 17, 2025, 9:55 a.m. to 10:45 a.m. Eastern
Dealing With The IRS In The Current Era
This session will guide practitioners on how to work effectively with the IRS after recent reductions in the agency’s workforce, changes in leadership, funding cuts, and shifts in the agency’s priorities. Melissa will be joined by Mary Slonina of KPMG.
Tuesday, November 18, 2025, 11:20 a.m. to 12:35 p.m. Eastern
Working Effectively with the Taxpayer Advocate Service
This session will provide attendees with a deeper understanding of the Taxpayer Advocate Service’s (TAS) role within the IRS, how to best advocate for clients using TAS, and how to identify the criteria that make TAS more likely to accept a case referral. Melissa will be joined by Rochelle Hodes of Crowe LLP.
You can learn more about the conference and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

National Conference of CPA Practitioners 2025 Accounting and Tax Symposium
2025-11-19 - 2025-11-21
Kostelanetz attorneys Megan L. Brackney and Karen Kelly will speak at the Nassau/Suffolk chapter of the National Conference of CPA Practitioners (NCCPAP) 2025 Accounting and Tax Symposium. The conference will take place November 19–21, 2025, at the Crest Hollow Country Club in Woodbury, NY.
Megan’s session, “Circular 230: Rules and Best Practices for Tax Return Positions, Interacting with the IRS, and Assisting Clients with Past Non-Compliance,” will discuss key provisions of Circular 230 and how to best advocate for your clients while staying compliant. The panel will be held on November 21, 2025, from 1:05 p.m. to 2:20 p.m.
Karen’s session, “The Times They Are a-Changing,” will discuss the types of cases that IRS Special Agents are now focused on under the current administration, how cases will be worked and referred for criminal prosecution going forward, and expectations for the future of voluntary compliance with the tax laws in the United States. The panel will be held on November 20, 2025, from 12:45 p.m. to 1:40 p.m.
The three-day symposium is co-sponsored by NCCPAP and the IRS, covering a wide variety of taxation topics. Attendees will have the opportunity to earn up to 27.5 continuing education credits and resolve their cases in person with senior IRS staff and New York State Department of Taxation and Finance representatives.
You can learn more about the symposium and register here.
About Megan
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the Chair of the American Bar Association Section of Taxation. She is also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations, and in criminal tax and white-collar state and federal matters.

12th Annual IRS Representation Conference
2025-11-19 13:00 - 17:00
Michael Sardar will speak on two panels at the 12th Annual IRS Representation Conference at the Foxwoods Resort Casino in Mashantucket, Conn., on November 19, 2025.
The IRS Representation Conference is the premier event for tax professionals who want to stay ahead of the fast-changing enforcement landscape. Leading attorneys, former IRS officials, and industry experts come together for a half-day program packed with insights, strategies, and practical tools you can use immediately in your practice.
The conference is from 1 p.m. – 5 p.m. Eastern. For more information, click here.
Michael’s panels include:

November 19, 2025, 1:00 pm – 2:00 pm
IRS Enforcement Update
Michael will be joined by Eric Green of Green & Sklarz LLC and Mary Beth Murphy, Former IRS SB/SE Commissioner.

November 19, 2025, 2:00 pm – 3:00 pm
Where’s My Money? Obtaining Refunds Amidst IRS Chaos
Michael will be joined by Jeffrey Sklarz and Lisa Perkins, both of Green & Sklarz LLC.

About Michael
Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.

2025 CBIT Fall Tax Day
2025-11-20 20:45
Megan L. Brackney will present a program on “Tax Controversy & Basics of Tax Procedure” at the 2025 Fall Tax Day hosted by the Committee of Banking Institutions on Taxation (CBIT).
The CBIT Fall Tax Day will be held on November 20, 2025, from 8:45 a.m. to 4:30 p.m. at the Arno Ristorante in New York, NY. Megan’s panel will be held at 2:30 p.m.
Learn more about the program here.
About Megan
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the Chair of the American Bar Association Section of Taxation. She is also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.

IRS Exam & Enforcement Trends: What Private Investment Funds Need to Know
2025-12-02 14:30 - 15:15
Caroline Ciraolo will join a panel titled IRS Exam & Enforcement Trends: What Private Investment Funds Need to Know, at the PIF Tax and Accounting Forum virtual conference on December 2, 2025, from 2:30 p.m. to 3:15 p.m. Eastern. Continuing education credit is available.
The panelists will address tax enforcement trends concerning partnerships and high-income taxpayers in light of recent changes at the IRS and areas of increased scrutiny that fund managers and investors should be mindful of. Attendees will learn how to effectively manage private investment fund audits and navigate re-established IRS guidance on investment entities.
Caroline will be joined by Jennifer Breen, partner at Morgan, Lewis & Bockius LLP, and Miri Forster, partner and National Tax Controversy & Dispute Resolution Leader at Eisner Advisory Group LLC.
You can learn more about the virtual conference and register here.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

NJCPA Bergen Chapter Federal Tax Update Seminar
2025-12-03 08:00 - 10:00
Frank Agostino will present a NJCPA federal tax update seminar for the Bergen County chapter at Bergen Community College Technology Education Center in Paramus, NJ on December 3, 2025, from 8 a.m. to 10 a.m. Eastern. Continuing education credit is available.
The seminar will cover the latest developments in federal tax enforcement, such as tax issues for influencers on TikTok and other platforms, the tax treatment of student-athlete NIL (name, image, and likeness) payments and sponsorships, AI in tax practices, and tax scams affecting practitioners and clients.
You can learn more about the seminar and register here.
About Frank
During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.

UT Law CLE 2025 Taxation Conference: What to Do With All the Data?
2025-12-04
Melissa Wiley will present a program titled “What to Do With All the Data? Substantiating Tax Positions in the Face of Tidal Waves of Data” at the University of Texas School of Law CLE 73rd Annual Taxation Conference. The conference is being held at the AT&T Conference Center in Austin, TX on December 4, 2025. Continuing education credits and virtual attendance options are available.
Melissa’s session takes place from 10:45 a.m. to 11:45 a.m. Central. In this session, Melissa will discuss the role of Big Data in how taxpayers and practitioners interface with tax authorities, and how to best advocate for clients in the Digital Age.
You can learn more about the conference and register here.

2025 ABA Criminal Tax Fraud and Tax Controversy Conference
2025-12-11 - 2025-12-13
Several Kostelanetz attorneys will speak on various panels of the 2025 ABA Criminal Tax Fraud and Tax Controversy Conference, of which Kostelanetz LLP is a proud sponsor. Our attorneys will demonstrate their knowledge and experience in tax controversy, high-profile developments in tax enforcement, criminal tax litigation, and more.
The conference will be held December 11-13, 2025, at the Wynn Las Vegas. Continuing education credit is available for most sessions. You can learn more about the conference and register here.
Please join us for the following panels:
Thursday, December 11, 2025, 10:30 a.m. to 12:30 p.m.
Low-Income Taxpayers Workshop: Tax Representation for Student Athletes, Performing Artists, Influencers, and Content Creators: Understanding NIL and Beyond
Counsel Frank Agostino will moderate a panel about unique tax issues that affect modern-day influencers, content creators, and sports stars. Just like yesteryear’s movie stars, independent content creators and influencers with brand deals have a bevy of unique tax issues. There are additional tax complexities surrounding Name, Image, and Likeness (NIL) income for student athletes that adds layers to advising pro athlete clients on the “jock tax”. Attendees will leave with a more comprehensive understanding of this high-profile practice area and its evolutions in self-employment taxes, entity selection, multi-state tax issues, royalty income, and IRS initiatives targeting these groups.
Other panel participants include Anthony DeRiso of Jones Day and Sarah Green of Dentons.

Thursday, December 11, 2025, 2:30 p.m. to 5:30 p.m.
Civil Tax Workshop: Nuts and Bolts of Tax Controversy Practice: Trying Your Tax Court Case in An Electronic Courtroom
Counsel Frank Agostino will moderate a panel on civil tax issues. Tax Court judges and experienced trial lawyers will come together to teach attendees basic skills in civil litigation in the context of specific issues and procedures. In this annual workshop that explores how technology constantly changes law practice, the speakers will demonstrate best practices for trying cases in electronic courtrooms.
Frank will be joined by The Hon. Ronald L. Buch and Hon. Mark V. Holmes, Senior Judge, of United States Tax Court will join Christopher Gurley of Crowell & Moring LLP, Rami Mitri Khoury of Taylor Nelson Amitrano LLP, and Sarah Ray of Dentons.

Thursday, December 11, 2025, 2:30 p.m. to 5:30 p.m.
Civil Tax Workshop: Nuts and Bolts of Tax Controversy Practice: Trying Your Tax Court Case in An Electronic Courtroom
Counsel Frank Agostino will moderate a panel on civil tax issues, focusing on how technology is revolutionizing Tax Court practice. From filing petitions to monitoring deadlines and preparing exhibits for filing with the Court and examining witnesses, technology shapes how we present cases. This seminar will review the latest technological advancements and discuss their impact on civil tax litigation. Tax Court judges and experienced trial lawyers will come together to share insights on basic skills in civil litigation in the context of specific issues and procedures, and demonstrate best practices for trying cases in electronic courtrooms.
Counsel Frank Agostino will moderate this session. The Hon. Ronald L. Buch, Judge, United States Tax Court; The Hon. Mark V. Holmes, Senior Judge, of United States Tax Court; Christopher Gurley of Crowell & Moring LLP; Rami Mitri Khoury of Taylor Nelson Amitrano LLP; and Sarah Ray of Dentons.

Thursday, December 11, 2025, 2:00 p.m. to 5:30 p.m.
Criminal Tax Workshop
Jay Nanavati will co-moderate a workshop where attendees will learn strategies and techniques for sensitive civil examinations, criminal investigations, and defending criminal prosecutions. Attendees will also receive a “criminal tax toolkit” of best practices from experienced practitioners. Workshop topics include when to anticipate a criminal referral, how to handle IRS Special Agent interviews of taxpayers and preparers, representing parties in criminal investigations, and more.
Mike Waalkes will introduce the workshop and Mary Wood of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, will co-moderate with Jay. They will be joined by Siana Danch of Holland & Knight LLP; Chad Nardiello of Nardiello Turanchik Tompkins LLP; Richard Speier of Richard Speier P.C.; and Anshuman A. Vaidya of Hinshaw & Culbertson LLP.

Friday, December 12, 2025, 8:40 a.m. to 9:25 a.m.
What Else Can We Do: Tax Controversy Practice in Challenging Times
Caroline Ciraolo will moderate this panel with former IRS Commissioners, Hon. Charles Rettig and Hon. Daniel Werfel, who will share their years of broad experience steering the IRS through myriad challenges.
This plenary panel will address taxpayer needs in an era where the IRS is expected to function with fewer resources, and the resources that exist are diverted to non-tax enforcement. How can tax controversy professionals utilize their skills to meet taxpayers’ needs and resolve cases?

Friday, December 12, 2025, 9:30 a.m. to 10:25 a.m.
Criminal Enforcement Priorities
Karen Kelly, Kostelanetz partner and the immediate past head of the Justice Department’s Tax Division, will participate in a roundtable of former IRS and DOJ leaders and prosecutors. The speakers will discuss hot topics and recent decisions in the criminal tax sphere in the context of current DOJ policies.
Sandra R. Brown of Hochman Salkin Toscher Perez P.C. will moderate. Karen will be joined in the roundtable by Guy Ficco, Chief, IRS Criminal Investigations; Elizabeth Hadden, Deputy Division Counsel, IRS Criminal Investigations; and Eric Hylton, National Director of Compliance, Alliantgroup.

Friday, December 12, 2025, 11:40 a.m. to 12:35 p.m.
Civil Tax: Exam, Collection, Appeals – Navigating Administrative Matters With a Reduced IRS Workforce
The IRS faces unprecedented challenges in resources, but taxpayers still need their civil tax matters resolved. Experienced practitioners will share their strategies and current approaches with attendees for navigating the current IRS landscape when handling existing examinations, IRS appeals, collections, and other civil tax matters.
Shan Kadkoy will introduce the session, which Guinevere Moore of Moore Tax Law Group will moderate. They will be joined by Abbey Garber of Holland & Knight LLP, Richard J. Sapinski of Sills Cummis & Gross P.C., and Carolyn Schenck of Caplin & Drysdale.

Saturday, December 13, 2025, 8:45 a.m. to 9:45 a.m.
Responding to Challenging Client Requests: Where Are the Ethical Lines?
Bryan Skarlatos will moderate a panel on the practical and ethical issues involved in addressing challenging requests from clients, such as assisting a client to use political influence to affect an audit or investigation, or seek a pardon. Or, whether a client can be extradited from a specific country, or can engage in asset protection planning.
Bryan will be joined by Michael J. Desmond of Miller & Chevalier; Diana Erbsen of DLA Piper; and Kathleen Pakenham of Vinson & Elkins LLP.

Saturday, December 13, 2025, 10:00 a.m. to 11:30 a.m.
Non-Traditional Tax Advocacy
Frank Agostino will moderate a session on non-traditional tax advocacy. Some tax cases cannot be resolved through standard procedures. How do you advocate for your client when letters to the IRS go unanswered, or Appeals is not responsive? This panel will discuss non-traditional routes to solving tax problems such as seeking redress from the Taxpayer Advocate Service and Treasury Inspector General for Tax Administration, contacting the client’s Congressional constituent services office, getting the Office of Professional Responsibility involved, and going to the media.
Frank will be joined by Stephen Cohen, Senior Managing Director and Co-Head, Transactions and Strategic Situations Group, Teneo; and Sharyn M. Fisk, Associate Professor at Cal Poly Pomona.

About Frank
During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations, including in criminal tax and white-collar matters, and against state and federal criminal charges.
About Jay
Jay is a criminal tax defense attorney and a fellow of both the American College of Trial Lawyers and the American College of Tax Counsel. He represents individuals and entities facing investigations and prosecutions by the IRS, the FBI, state investigative agencies, U.S. Attorney’s offices, and the Department of Justice Tax Division. Jay has defended clients against federal investigations and charges throughout the country, and he has substantial experience representing clients accused of promoting or participating in so-called tax shelters, including captive insurance programs, conservation easements, and Puerto Rico’s Act 20/Act 22 program. In many instances, Jay represents tax professionals facing such accusations.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.
About Mike
Mike received his J.D. and LL.M. in taxation from Boston University School of Law. During law school, he worked as an intern for the low-income taxpayer clinic at Harvard Law School’s Legal Services Center, as a research assistant for Professor T. Keith Fogg of Harvard Law School, and as a summer associate and a law clerk with Kostelanetz. Mike also served as an editor on the Review of Banking and Financial Law journal. Prior to law school, Mike worked as a paralegal at a tax controversy firm in the D.C. metro area.
About Shan
Shan began his legal career as a Judicial Law Clerk to the Honorable Mary Siobhan Brennan, J.T.C., in the Tax Court of New Jersey. Prior to joining the firm, Shan practiced at Agostino & Associates P.C., as well as at another firm, concentrating his practice in Wills, Trusts & Estates, and Business Law.

Public Records: A Legal Primer for Attorneys
2025-12-16 15:00 - 16:00
Usman Mohammad will present a webinar for the National Business Institute (NBI) titled Public Records: A Legal Primer for Attorneys. The webinar is on December 16, 2025, and will run from 3 p.m.-4 p.m. Eastern.
In the webinar, Usman will show attendees how to effectively navigate public records and gain critical information to advocate for clients. The webinar will begin with an overview of federal and state laws, including Freedom of Information Act (FOIA) requests and the types of information that is typically available via public record. Attendees will learn best practices for drafting and filing public record requests, as well as how to handle common causes of public record request denials and delays.
You can learn more about the webinar and register here.
About Usman
Usman is counsel at the New York City office of Kostelanetz LLP. Usman’s practice includes New York City and State government procurement matters, civil and criminal tax controversies including tax whistleblower matters, and commercial litigation.
