Several Kostelanetz attorneys will be speaking at the 13th Annual IRS Representation Conference, to be held July 15-17, 2026, at the Foxwoods Hotel and Casino in Mashantucket, Connecticut.
The conference features leading attorneys, former IRS officials, and industry experts for programs packed with insights, strategies, and practical tools for use in tax practice.
Learn more about the event here.
Kostelanetz attorney will participate in the panels below:
Wednesday, July 15, 2026, 9 am
What’s Hot and What’s Not: 2026 Enforcement Update
Chris Ferguson will participate in a panel that will review what is hot right now in terms of IRS enforcement, including ERC Audits, defaulted SBA Loans, high net-worth audits, digital assets and cryptocurrency, reasonable compensation audits of S Corporations, employment tax issues and worker classification, and abusive tax shelters.
Other speakers include moderator Sara Neill of Neill, Schwerin & Boxerman, P.C., and panelists Dan Mayo of Withum and James Grimaldi of Citrin Cooperman.
Wednesday, July 15, 2026, 10:10 am
IRS Audits Under the Centralized Partnership Audit Regime (BBA)
Andrew Weiner will participate on a panel about IRS audits under the centralized partnership audit regime of the Bipartisan Budget Act (“BBA”), which was signed into law on November 2, 2015, and replaced the partnership audit procedures for partnerships under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”). The BBA represents a major change in the way adjustments are made to how partnerships are audited and how partnerships make changes to their prior year returns. BBA audits have been on the rise with revenue agents and tax professionals working together to navigate filing and notice requirements, imputed underpayment computations and adjustments, push out elections, and litigation of BBA matters in court. This panel will provide an overview of the complex rules contained in the centralized partnership audit regime and provide practitioners with the information they need to know to accurately spot issues and advise their clients for both filing and in the event of a BBA audit.
Other speakers include Robert Day of Green & Sklarz LLC, and fellow panelist Jenni Black of Citrin Cooperman.
Thursday, July 16, 2026, 9 am
Where’s My Money? Bringing a Refund Action
Chris Ferguson will participate in a panel on refund actions. With the current chaos at the IRS, more and more taxpayers are waiting for refunds that may or may not ever show up. These taxpayers and their professionals are often not aware the clock is ticking for them to bring an action and obtain their refund. This panel will review the statutory requirements for refunds, deadlines you need to be aware of, and how to bring a refund action against the government.
Other speakers include moderator Jeffrey Sklarz of Green & Sklarz LLC, and fellow panelist Walter Pagano of Eisner Advisory, LLC.
Thursday, July 16, 2026, 3:10 pm
Freedom of Information Act Requests: The Benefits and Limitations of FOIA
Michael Sardar will participate in a panel on the benefits and limitations of FOIA requests. Maybe the client was audited, has been assessed a trust fund recovery penalty, or is the subject of a criminal investigation after dealing with the IRS Collections Division. There are many reasons why it would be helpful to look at what the IRS file says about the taxpayer and their situation. This panel will discuss the mechanics of drafting and filing a request under the Freedom of Information Act, including what records are available, what records might be withheld pursuant to various exemptions, and how best to make use of that information to help your taxpayer.
Other speakers include moderator Lisa E. Perkins of Green & Sklarz LLC, and fellow panelist Walter Pagano of Eisner Advisory, LLC.
About Chris
Chris Ferguson has over two decades of experience as a litigator, concentrating his practice on white-collar criminal defense as well as civil and criminal tax controversies and other regulatory enforcement matters. Chris also has extensive experience handling complex civil litigation and internal investigations.
About Michael
Michael has extensive experience on a wide range of tax controversy and white-collar criminal defense matters, and he represents clients in all stages of civil and criminal tax controversies before the IRS, state tax authorities, the Department of Justice, and local prosecutors. Additionally, Michael represents clients in gift and estate tax audits, where he is called upon to assist taxpayers in challenging the IRS’s valuation of gifts and bequests and/or the includability of certain transfers.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has briefed and argued approximately 50 tax cases in the U.S. courts of appeals. He is regent of the American College of Tax Counsel for the D.C. Circuit and a frequent writer and speaker on tax issues. He is also an adjunct professor at American University Washington College of Law.
