Kostelanetz attorneys will speak on various panels of the ABA 2026 Midyear Tax Meeting, of which Kostelanetz LLP is a proud sponsor. Our attorneys will demonstrate their knowledge and experience in tax controversy, new developments in tax enforcement, and more.
The conference will be held January 15 to January 17, 2026, at the Marriott Marquis San Diego Marina. 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:
Friday, Jan. 16, 2026, 2:30 p.m.
Tax Litigation in a Resource-Constrained Environment: Trends, Challenges, and Ethical Considerations for Practitioners
Caroline Ciraolo will speak on a panel addressing how practitioners are navigating tax litigation during these challenging times of limited resources and shifting priorities in tax administration and enforcement. Panelists will offer insight into managing client expectations, maintaining case timelines, deadlines, and trial calendars, pursuing alternative dispute resolution, negotiating settlements, and staying within the ethical guardrails. (Ethics Credit)
Caroline will be joined by moderator Darianne De Leon, Pillsbury Winthrop Shaw Pittman, and fellow panelists Michael J. Desmond, Miller & Chevalier and A. Lavar Taylor, Taylor Nelson Amitrano LLP.
Friday, Jan. 16, 2026, 3:45 p.m.
IRS Scrutiny of Pandemic Relief: Enforcement Trends in ERC and EIDL
Jay Nanavati will moderate a panel about IRS enforcement efforts regarding potential abuse of pandemic-era relief programs, such as the Employee Retention Credit and the Economic Injury Disaster Loan programs.
Jay will be joined by panelists Guinevere M. Moore, Moore Tax Law Group LLC; Daniel Strickland, Holland & Knight; and Francesca Ugolini, SouthBank Legal.
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 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.
Friday, Jan. 16, 2026, 1:00 p.m.
Criminal Tax 101: Exploring the Ins and Outs of a Criminal Tax Investigation and the Particular Risks that Tax-Exempt Organizations Face
Karen Kelly will participate in a panel addressing how tax-exempt organization practitioners have been navigating new areas of the tax laws over the past year and how criminal tax laws are now on that list. The panelists will provide an overview of the process of a criminal tax investigation, highlight the potential triggers of such an investigation and the particular risks that tax-exempt organizations face, and discuss best practices for responding to and navigating a criminal tax investigation.
Karen will be joined by moderator Alexander Reid of BakerHostetler and fellow panelist Joseph Rillotta of Meadows Collier.
About Karen
The former acting 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 adverse to the government, including in criminal matters, and state and federal civil tax controversies.
