FALLS CHURCH, VA — Tax Analysts' flagship publication, Tax Notes, the longtime industry standard for federal tax news, commentary, and analysis, introduced a new regular column today, The Tax Controversy & Litigation Report, written by contributor Charles P. Rettig. Effective client representation requires an understanding of the relevant facts, a detailed knowledge of the applicable tax authorities, and respect for current IRS enforcement priorities and initiatives together with an understanding of professional and ethical responsibilities. The first installment, "Current Enforcement Priorities — Reading Tea Leaves in a Tax Gap Environment," highlights selected enforcement priorities, as framed by provisions within the IRS’s strategic plan focusing on practitioners, and suggests responsive techniques and strategies. The column will provide detailed, practical advice designed to assist practitioners working in the tax trenches.
Future Reports will address the impact on a subsequent examination of specific information included — or not — within the income tax return; administrative options in the representation of clients with undisclosed foreign financial accounts; pre-audit issue preparation and interview techniques; compliance with Circular 230; professional responsibilities and methods of avoiding preparer penalties and sanctions. And also, the reports will discuss emerging issues and developments of interest in federal tax controversy and tax litigation (civil and criminal) and will provide perspectives for tax practitioners and their clients involved in various stages of the federal administrative process, together with discussions of selected recent cases and IRS guidance with timely, practical recommendations. Rettig will also consider future Reports on additional topics suggested by practitioners.
About the Author:
Rettig, a principal with Hochman, Salkin, Rettig, Toscher & Perez P.C. of Beverly Hills, Calif., is a frequent author and lecturer on matters involving federal and state, and civil and criminal, tax controversy and tax litigation. He was recently selected one of the "most influential tax persons for 2009"; is a regent and an elected fellow of the American College of Tax Counsel; is vice-chair of the IRS Advisory Council (IRSAC); and is on the national board of advisors for the Graduate Tax Program (LLM in Taxation) at New York University School of Law. Articles by Rettig previously published in Tax Notes include "Practitioner Penalties: Potential Pitfalls in the Tax Trenches" (April 13, 2009) and the "Tax Practitioners Guidebook: Picking Up Table Scraps" (March 12, 2007). Rettig is the chair of the Committee on Civil and Criminal Tax Penalties of the American Bar Association Tax Section. He is a past chair of the Section of Taxation for the State Bar of California and has received numerous awards from many different professional bar and accounting organizations honoring his ongoing, significant contributions to the tax community.
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