Several Kostelanetz attorneys will speak on various panels of the 2025 ABA Criminal Tax Fraud and Tax Controversy Conference, of which Kostelanetz LLP is a proud sponsor. Our attorneys will demonstrate their knowledge and experience in tax controversy, high-profile developments in tax enforcement, criminal tax litigation, and more.

The conference will be held December 11-13, 2025, at the Wynn Las Vegas. Continuing education credit is available for most sessions. You can learn more about the conference and register here.

Please join us for the following panels:

Thursday, December 11, 2025, 10:30 a.m. to 12:30 p.m.

Low-Income Taxpayers Workshop: Tax Representation for Student Athletes, Performing Artists, Influencers, and Content Creators: Understanding NIL and Beyond

Counsel Frank Agostino will moderate a panel about unique tax issues that affect modern-day influencers, content creators, and sports stars. Just like yesteryear’s movie stars, independent content creators and influencers with brand deals have a bevy of unique tax issues. There are additional tax complexities surrounding Name, Image, and Likeness (NIL) income for student athletes that adds layers to advising pro athlete clients on the “jock tax”. Attendees will leave with a more comprehensive understanding of this high-profile practice area and its evolutions in self-employment taxes, entity selection, multi-state tax issues, royalty income, and IRS initiatives targeting these groups.

Other panel participants include Anthony DeRiso of Jones Day and Sarah Green of Dentons.

 

Thursday, December 11, 2025, 2:30 p.m. to 5:30 p.m.

Civil Tax Workshop: Nuts and Bolts of Tax Controversy Practice: Trying Your Tax Court Case in An Electronic Courtroom

Counsel Frank Agostino will moderate a panel on civil tax issues. Tax Court judges and experienced trial lawyers will come together to teach attendees basic skills in civil litigation in the context of specific issues and procedures. In this annual workshop that explores how technology constantly changes law practice, the speakers will demonstrate best practices for trying cases in electronic courtrooms.

Frank will be joined by The Hon. Ronald L. Buch and Hon. Mark V. Holmes, Senior Judge, of United States Tax Court will join Christopher Gurley of Crowell & Moring LLP, Rami Mitri Khoury of Taylor Nelson Amitrano LLP, and Sarah Ray of Dentons.

 

Thursday, December 11, 2025, 2:30 p.m. to 5:30 p.m.

Civil Tax Workshop: Nuts and Bolts of Tax Controversy Practice: Trying Your Tax Court Case in An Electronic Courtroom

Counsel Frank Agostino will moderate a panel on civil tax issues, focusing on how technology is revolutionizing Tax Court practice. From filing petitions to monitoring deadlines and preparing exhibits for filing with the Court and examining witnesses, technology shapes how we present cases. This seminar will review the latest technological advancements and discuss their impact on civil tax litigation. Tax Court judges and experienced trial lawyers will come together to share insights on basic skills in civil litigation in the context of specific issues and procedures, and demonstrate best practices for trying cases in electronic courtrooms.

Counsel Frank Agostino will moderate this session. The Hon. Ronald L. Buch, Judge, United States Tax Court; The Hon. Mark V. Holmes, Senior Judge, of United States Tax Court; Christopher Gurley of Crowell & Moring LLP; Rami Mitri Khoury of Taylor Nelson Amitrano LLP; and Sarah Ray of Dentons.

 

Thursday, December 11, 2025, 2:00 p.m. to 5:30 p.m.

Criminal Tax Workshop 

Jay Nanavati will co-moderate a workshop where attendees will learn strategies and techniques for sensitive civil examinations, criminal investigations, and defending criminal prosecutions. Attendees will also receive a “criminal tax toolkit” of best practices from experienced practitioners. Workshop topics include when to anticipate a criminal referral, how to handle IRS Special Agent interviews of taxpayers and preparers, representing parties in criminal investigations, and more.

Mike Waalkes will introduce the workshop and Mary Wood of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, will co-moderate with Jay. They will be joined by Siana Danch of Holland & Knight LLP; Chad Nardiello of Nardiello Turanchik Tompkins LLP; Richard Speier of Richard Speier P.C.; and Anshuman A. Vaidya of Hinshaw & Culbertson LLP.

 

Friday, December 12, 2025, 8:40 a.m. to 9:25 a.m.

What Else Can We Do: Tax Controversy Practice in Challenging Times

Caroline Ciraolo will moderate this panel with former IRS Commissioners, Hon. Charles Rettig and Hon. Daniel Werfel, who will share their years of broad experience steering the IRS through myriad challenges.

This plenary panel will address taxpayer needs in an era where the IRS is expected to function with fewer resources, and the resources that exist are diverted to non-tax enforcement. How can tax controversy professionals utilize their skills to meet taxpayers’ needs and resolve cases?

 

Friday, December 12, 2025, 9:30 a.m. to 10:25 a.m.

Criminal Enforcement Priorities

Karen Kelly, Kostelanetz partner and the immediate past head of the Justice Department’s Tax Division, will participate in a roundtable of former IRS and DOJ leaders and prosecutors. The speakers will discuss hot topics and recent decisions in the criminal tax sphere in the context of current DOJ policies.

Sandra R. Brown of Hochman Salkin Toscher Perez P.C. will moderate. Karen will be joined in the roundtable by Guy Ficco, Chief, IRS Criminal Investigations; Elizabeth Hadden, Deputy Division Counsel, IRS Criminal Investigations; and Eric Hylton, National Director of Compliance, Alliantgroup.

 

Friday, December 12, 2025, 11:40 a.m. to 12:35 p.m.

Civil Tax: Exam, Collection, Appeals – Navigating Administrative Matters With a Reduced IRS Workforce

The IRS faces unprecedented challenges in resources, but taxpayers still need their civil tax matters resolved. Experienced practitioners will share their strategies and current approaches with attendees for navigating the current IRS landscape when handling existing examinations, IRS appeals, collections, and other civil tax matters.

Shan Kadkoy will introduce the session, which Guinevere Moore of Moore Tax Law Group will moderate. They will be joined by Abbey Garber of Holland & Knight LLP, Richard J. Sapinski of Sills Cummis & Gross P.C., and Carolyn Schenck of Caplin & Drysdale.

 

Saturday, December 13, 2025, 8:45 a.m. to 9:45 a.m.

Responding to Challenging Client Requests: Where Are the Ethical Lines?

Bryan Skarlatos will moderate a panel on the practical and ethical issues involved in addressing challenging requests from clients, such as assisting a client to use political influence to affect an audit or investigation, or seek a pardon.  Or, whether a client can be extradited from a specific country, or can engage in asset protection planning.

Bryan will be joined by Michael J. Desmond of Miller & Chevalier; Diana Erbsen of DLA Piper; and Kathleen Pakenham of Vinson & Elkins LLP.

 

Saturday, December 13, 2025, 10:00 a.m. to 11:30 a.m.

Non-Traditional Tax Advocacy

Frank Agostino will moderate a session on non-traditional tax advocacy. Some tax cases cannot be resolved through standard procedures. How do you advocate for your client when letters to the IRS go unanswered, or Appeals is not responsive? This panel will discuss non-traditional routes to solving tax problems such as seeking redress from the Taxpayer Advocate Service and Treasury Inspector General for Tax Administration, contacting the client’s Congressional constituent services office, getting the Office of Professional Responsibility involved, and going to the media.

Frank will be joined by Stephen Cohen, Senior Managing Director and Co-Head, Transactions and Strategic Situations Group, Teneo; and Sharyn M. Fisk, Associate Professor at Cal Poly Pomona.

 

About Frank

During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.

About Caroline

Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

About Karen

The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations, including in criminal tax and white-collar matters, and against state and federal criminal charges.

About Jay

Jay is a criminal tax defense attorney and a fellow of both the American College of Trial Lawyers and the American College of Tax Counsel. He represents individuals and entities facing investigations and prosecutions by the IRS, the FBI, state investigative agencies, U.S. Attorney’s offices, and the Department of Justice Tax Division. Jay has defended clients against federal investigations and charges throughout the country, and he has  substantial experience representing clients accused of promoting or participating in so-called tax shelters, including captive insurance programs, conservation easements, and Puerto Rico’s Act 20/Act 22 program. In many instances, Jay represents tax professionals facing such accusations.

About Bryan

Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.

About Mike

Mike received his J.D. and LL.M. in taxation from Boston University School of Law. During law school, he worked as an intern for the low-income taxpayer clinic at Harvard Law School’s Legal Services Center, as a research assistant for Professor T. Keith Fogg of Harvard Law School, and as a summer associate and a law clerk with Kostelanetz. Mike also served as an editor on the Review of Banking and Financial Law journal. Prior to law school, Mike worked as a paralegal at a tax controversy firm in the D.C. metro area.

About Shan

Shan began his legal career as a Judicial Law Clerk to the Honorable Mary Siobhan Brennan, J.T.C., in the Tax Court of New Jersey. Prior to joining the firm, Shan practiced at Agostino & Associates P.C., as well as at another firm, concentrating his practice in Wills, Trusts & Estates, and Business Law.