Webinar: Independence Day: Appeals, Refund Claims, and the Taxpayer Advocate Under the TAS Act by ALFi

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Presenters

Elizabeth P. Askey

Of Counsel, Tax Controversy and Litigation

Ms. Askey’s practice spans a variety of domestic and international tax issues, and she has extensive experience in controversy mitigation strategies, including private letter rulings, closing agreements, prefiling agreements, industry issue resolutions, and regulatory and legislative tax policy advocacy.

Ms. Askey joined Skadden after serving in several high-level positions at the IRS, including most recently as Chief of the Independent Office of Appeals (Appeals). In this role, she set strategy and oversaw the operations of nearly 1,800 Appeals employees and programs designed to resolve tax controversies between taxpayers and the IRS without litigation. She also previously served as Deputy Chief of Appeals. Prior to these roles, she served as Deputy Division Counsel (International) for the IRS Office of Chief Counsel’s Large Business and International (LB&I) Division, where she directed the work of approximately 350 attorneys and paralegals responsible for litigating LB&I cases and providing advice to exam teams and Appeals. Earlier in her career, Ms. Askey served as an attorney-advisor and associate tax legislative counsel in the Office of Tax Policy at the Department of the Treasury (Treasury).

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.

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-00034-26-O

For a controversy practice, this may be the most consequential hour of the series. The TAS Act would strengthen the independence of the IRS Independent Office of Appeals and, for the first time, require the IRS to respond to a refund claim within a defined period, give taxpayers a detailed written explanation of any disallowance, and provide a statutory right to appeal that disallowance—suspending the two-year period to file suit while the appeal is pending. We'll examine the bill's codification of Appeals' duty to weigh the hazards of litigation, its clarified right of appeal, and new authority for Appeals to hire its own counsel. The session then turns to an expanded Taxpayer Advocate Service—including the National Taxpayer Advocate's access to IRS legal advice and continued operations during a lapse in appropriations. Attendees will leave knowing where the bill would give clients a stronger administrative path and a better record for any later suit.

Agenda

Identify the TAS Act's proposed requirements for the IRS to respond to, and explain the disallowance of, refund claims
Explain the new statutory right to appeal a refund-claim disallowance and its suspension of the period to file suit
Describe the codified duty of the Independent Office of Appeals to weigh the hazards of litigation and the clarified right of appeal
Recognize the proposed expansions of Taxpayer Advocate Service authority, including access to IRS legal advice and operations during an appropriations lapse
Evaluate when the expanded Appeals and Taxpayer Advocate authority would offer a client a better path