Tax Section: Practice and Procedure Roundtable Call

Practical Implications of the Current Pandemic on Tax Controversy Work

Join the Tax Law Section on May 21 from 12:00 to 1:00 pm Eastern for a discussion on the practical issues facing tax controversy attorneys during this time of modified court and IRS operations. Sean Akins, Chris Rizek, and Daniel Strickland will be talking about the new issues and challenges faced in administrative controversy, litigation, and collections. They will also be offering their insight into how to anticipate and avoid potential pitfalls throughout the remainder of our collective time working from home.

About the Speakers

Sean Akins is a partner at Covington & Burling LLP in Washington, D.C. He is also the co-author of Kafka, Cavanagh, & Akins, Litigation of Federal Civil Tax Controversies, 2d ed., the leading two-volume treatise on the litigation of tax cases in the United States. In his practice, Mr. Akins, advises corporations, partnerships, international organizations and tax-exempt entities on Federal tax litigation and controversy matters. Mr. Akins has extensive experience litigating before the U.S. Tax Court, Court of Federal Claims, and the U.S. District and Appellate Courts. In addition to litigating tax matters, Mr. Akins also provides strategic advice with respect to navigating the Internal Revenue Service administratively. This involves representing clients before the IRS Office of Appeals, in Fast Track proceedings, in connection with standard and CAP-based audits, and in the obtaining of private rulings from the IRS on substantive issues. Mr. Akins also assists clients in responding to Congressional and other administrative tax investigations.

Christopher S. Rizek is a Member in Caplin & Drysdale’s Washington, D.C., office. He also serves as General Counsel to the firm. Since 2013, The Legal 500 has listed Mr. Rizek as an elite “Leading Lawyer” for his contributions to tax controversy law. Mr. Rizek represents taxpayers in all types of federal civil and criminal tax controversy matters. He also guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases in U.S. district and appellate courts, the U.S. Court of Federal Claims, and the U.S. Tax Court. In recent years, he has represented numerous financial and professional firms in connection with IRS examinations of tax shelters and related compliance and professional ethics issues. Mr. Rizek formerly served as Associate Tax Legislative Counsel in the U.S. Treasury Department, Office of Tax Policy, where he helped write tax procedural guidance and legislation, including particularly the Taxpayer Bill of Rights 2 (1996) and the IRS Restructuring and Reform Act of 1998. He has also previously worked in other Washington law firms and as a Trial Attorney in the U.S. Department of Justice, Tax Division.

Daniel Strickland is an associate at Eversheds Sutherland (US) LLP in Washington, D.C. He concentrates his practice in the area of federal and international tax controversy, representing taxpayers in all types of tax controversy matters. Mr. Strickland guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases throughout the United States. His experience covers a wide range of complex tax issues, including valuation, foreign and energy tax credits, classification of investment as debt or equity, judicial substance doctrines, and penalty defenses. Prior to joining Eversheds Sutherland, Mr. Strickland served as a law clerk at the United States Tax Court for the Honorable Albert G. Lauber, the Honorable Elizabeth Crewson Paris, and the Honorable Michael B. Thornton.

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