Section on Taxation: Tax Practice and Procedure Roundtable: What’s Really Stopping Taxpayers? A Discussion of CIC Services and the Anti-Injunction Act

This roundtable will discuss the current status of the CIC Services case, the arguments that each side and amici presented, and thoughts on the Supreme Court’s upcoming ruling. The discussion will also provide helpful background on the Anti-Injunction Act, historical developments with respect to the Anti-Injunction Act, and will provide strategic considerations for practitioners wishing to overcome an Anti-Injunction Act defense made by the government.

About the Speakers

Joseph (Jud) B. Judkins, partner at Baker & McKenzie LLP, centers his practice on federal tax controversy matters at every phase of a dispute, including audit, IRS Appeals, and litigation. The application of administrative law principles to Treasury regulations and IRS guidance is a core component of his practice. Jud advises clients on a broad spectrum of international and domestic tax matters, including challenges to the validity of regulations, participation in the agency rulemaking process through the submission of comments and testimony at public hearings, the scope and application of TCJA regulations, transfer pricing disputes, tax statutory and regulatory interpretation, and other domestic and international tax issues. Prior to joining Baker & McKenzie, Jud was a law clerk at the United States Tax Court and a member of the US Navy JAG Corps. Jud received his LL.M. from Georgetown University Law Center and his J.D. from Wake Forest University.

David W. Foster, partner at Skadden Arps LLP, focuses his practice on federal tax controversy matters. David represents a broad range of clients, including large corporations, private equity firms and hedge funds, estates, exempt organizations and individuals, many of whom are subject to the IRS’ global high wealth initiative. His practice covers a diverse range of tax issues, including international tax, taxation of financial products, estate and gift taxes, proposed exempt status revocations, voluntary disclosures and criminal tax. David received his J.D. from Harvard Law School and his A.B. from Harvard University.

Ground Rules

1. Statements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.
2. No recording devices allowed.
3. FBA Tax Section membership is not required to participate, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.

Interested in Speaking?

If you are interested in leading a future monthly call, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com

If you have any questions regarding this program, please contact Laura Mulhern, Sections and Divisions Manager.