Webinar: Docket Like It's Hot: Tax Court and Judicial Review Under the TAS Act by ALFi

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Presenters

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

Terry Lemons

Director of Public Relations

From running communications and outreach for a major government agency to covering Congress and the White House as a reporter, Lemons has decades of experience inside and outside government.

During more than 26 years at the Internal Revenue Service, he played a pivotal role overseeing the tax agency’s communications and outreach efforts to taxpayers and tax professionals. His behind-the-scenes duties included advising six different IRS Commissioners, creating the IRS “Dirty Dozen” tax scams list in 2002, establishing the innovative IRS social media program as well as working closely with the tax professional and legal communities on tax compliance and taxpayer service issues.

About

Program Field of Study: Taxes | Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, Attorneys
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00035-26-O

The TAS Act would give the Tax Court its biggest jurisdictional expansion in decades. This session covers proposed refund suit jurisdiction (including a new path to sue for a refund without full prepayment of the tax), authority to determine the underlying liability and order refunds in collection due process cases, de novo review of innocent spouse determinations, and revised standards for whistleblower award determinations. We'll examine clarified—and newly flexible—filing deadlines, a regime moving certain assessable penalties into deficiency procedures, an increased small-case threshold, and changes to the Tax Court itself involving expanded special trial judge authority and new disqualification rules. Attendees will leave knowing which disputes could be litigated differently if the bill becomes law and what that means for case strategy today.

Agenda

Identify the proposed expansions of Tax Court jurisdiction, including refund suits and the option to sue without full payment of the tax
Explain the proposed authority to determine liability and order refunds in collection due process cases
Describe the de novo standard proposed for innocent spouse relief and the revised standards for whistleblower award determinations
Compare current and proposed filing deadlines, the treatment of certain assessable penalties, and the small-dispute threshold
Recognize structural changes to Tax Court operations, including special trial judge authority and disqualification standards