Skip to main content
Loading Events

« All Events

  • This event has passed.

Section on Taxation: Views on LB&I’s Proposal to Obsolete Revenue Procedure 94-69

November 19, 2020 @ 12:00 pm - 1:00 pm

This roundtable will discuss the status of Revenue Procedure 94-69. In August, the LB&I announced that it is considering rescinding Rev. Proc. 94-69. Rev. Proc. 94-69 provides special procedures for taxpayers that are subject to the former Coordinated Examination Program to show additional tax due or make disclosures to avoid the imposition of accuracy-related penalties for negligence, disregard of rules or regulations, or substantial understatement of income tax under IRC section 6662(b)(1) and (b)(2). Those who support retaining Rev. Proc. 94-69 argue that it ensures that taxpayers with large and complex returns are able to efficiently report and fix errors, which encourages compliance. Critics have noted that Rev. Proc. 94-69 creates disparity among LB&I taxpayers and fails to support the broader tax administration effort to improve the accuracy and reliability of returns at the time of filing. The panel will discuss their views on how this proposed change would affect taxpayers and comments that were submitted to the IRS.


About the Speakers

Lee Meyercord focuses her practice on federal, state, and local taxation of corporations, partnerships, individuals, and nonprofit organizations. She provides clients with tax planning advice on mergers and acquisitions, the operation and dispositions of partnerships and limited liability companies, and private equity transactions, and represents taxpayers in IRS audits, appeals, and federal income tax litigation. Lee also counsels clients on the organization, operation, and termination of nonprofit corporations and trusts, and obtaining and maintaining exemptions for these organizations from federal income, state franchise, sales and use, and local ad valorem taxes.

 

Kevin Stults concentrates his practice on federal tax controversy and litigation. He represents large financial institutions, multinational corporations and individuals at various stages of federal income tax controversies, including audits, administrative appeals and judicial proceedings. Mr. Stults’ substantive experience encompasses a variety of complex tax issues, including foreign tax credits, economic substance/business purpose, corporate restructurings, life insurance, various partnership issues, IRS promoter examinations, pre-filing agreements, and the TEFRA partnership audit and litigation procedures.

 


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 sections@fedbar.org

Details

Date:
November 19, 2020
Time:
12:00 pm - 1:00 pm
Event Category:

Venue

Online
US