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Section on Taxation: Recent Developments in Civil and Criminal Tax Controversies
Mr. Elliott and Mr. Pelak will be covering a wide range of current developments in civil and criminal tax controversies. Topics include recent IRS budgetary issues, remote trial procedures in the tax court, IRS Office of Promoter Investigations, conservation easements, virtual currency, and section 6695A and Form 3520 penalties.
Presented by: Section on Taxation
About the Presenters
W. Curtis Elliott, Partner, Culp Elliott & Carpenter, LLC
Curtis Elliott has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. His focus is primarily on civil tax cases, and he has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott’s clients include Fortune 500 companies, entrepreneurial companies, trusts and estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a fellow in the American College of Tax Counsel, where he has served on the Board of Regents, and is a fellow in the American College of Trusts and Estates Counsel. Curtis is very active in the ABA Section of Taxation, where he has served as past Chair of the Committee on Court Practice and Procedure, the Committee on Appointments to the Tax Court and Council. He speaks at conferences across the country on tax controversy topics. He also co-authored the nationally published workbook entitled “Valuation Practice in Estate Planning and Litigation” (Clark Boardman Callahan, 1994).
Richard A. Pelak, Partner, Culp Elliott & Carpenter, LLC
Richard A. Pelak serves as the Senior Tax Manager for the Firm’s Tax Compliance Group, CEC Advisors. Rich’s primary focus is on representing clients in various federal and state tax matters. This includes personal and business tax planning, consulting and compliance and representation before the IRS and other taxing authorities. He also assists clients in the areas of succession planning, estate planning and various business transactions. Rich has extensive experience in international tax matters and in recent years has been heavily involved in offshore bank account reporting issues. He has experience in compliance with the offshore voluntary disclosure issues and IRS amnesty programs. He has worked extensively with clients in analyzing foreign accounts and preparing the necessary tax filings.
Registration & Attendance Information
Registration for this event will close Monday, May 30 at 2 PM ET.
Registration Fees
- FBA Members & Nonmembers: Complimentary Registration
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.
Registrants will receive Zoom login details on the day before the event