9th Annual USD School of Law - RJS LAW Tax Controversy Institute

• Conference - Nexus Theater, Knauss Center for Business Education
• Reception - Garden of the Sea, Joan B. Kroc Institute for Peace & Justice, USD

The 9th Annual USD School of Law – RJS LAW Tax Controversy Institute will be held on Friday, July 19, 2024. The Institute is the premier tax controversy event in San Diego. The region's top tax attorneys, CPAs, and law/business school professors will discuss topics including government loan relief and abuses, challenges in cross-border transactions, and practical and realistic solutions in Trust, Estate Planning, and Tax matters.

The Richard Carpenter Excellence in Tax Award is given to an individual who exemplifies honesty, integrity, ethics, and compassion throughout his/her careers in the field of tax controversy and has demonstrated outstanding dedication and expertise while representing taxpayers before the federal and state governments.

Over the past 39 years, Richard Carpenter has been the leading IRS tax specialist in San Diego. He has devoted his entire legal career to defending hardworking taxpayers against the powerful reaches of the Internal Revenue Service. He began his career as a CPA when he worked for an international CPA firm in the Wall Street section of New York City. He then decided to attend law school where he received his Juris Doctor law degree from the University of San Diego School of Law.

We continue to humbly request and encourage your support of USD School of Law’s Tax Law Student Scholarship Fund, especially this year in light of the growing impact of COVID-19. As always, we are incredibly appreciative of your support.

7:30 a.m. - Registration & Continental Breakfast

8:30 a.m. - 9:00 a.m. - Introductory Speaker & Opening Remarks

• Paul Yong, Professor of Practice; Director of Graduate Tax Programs, USD School of Law; Vice President - Chief Tax Counsel, Sempra Energy
• Ryan Korner, Director of Field Operations at IRS: Criminal Investigation

9:00 a.m. - 10:00 a.m. - Estate Planning Panel: Practical and Realistic Solutions in Trust, Estate Planning, & Tax Matters

• Moderator: Brian Malloy, Of Counsel, RJS LAW
• Jenny Hill Bratt '06 (JD), Partner, Withers Bergman LLP
• DeEtte L. Loeffler, JD, '07 (LLM Taxation) Taxation, Founder, DeEtte L. Loeffler, a Professional Law Corporation
• Brent Wilsey, President, Wilsey Asset Management

1 0:00 a.m.-10:10 a.m. - BREAK

10:10 a.m. - 11:10 a.m. - International Tax Panel: Challenges of Cross-Border Transactions

• Moderator: Andrea Cisneros Valdez '17 (LLM), Of Counsel, RJS LAW
• Darren Guillot, Deputy Commissioner, SB/SE Collection & Operations Support, IRS
• Mary Robberson, Partner, Robberson Shroedter
• A. Lavar Taylor, Managing Partner, Taylor Nelson Amitrano LLP

1 1:10 a.m. -11:20 a.m. - BREAK

11:20 a.m. - 12:20 p.m. - Hotly Litigated Factual and Legal Issues in Trust Disputes

• Moderator: Jeryll S. Cohen, Partner, Freeman Freeman & Smiley LLP
• Robert "Robbie" Barton, Partner, McDermott, Will and Emery LLP
• David Greco, '14 (LLM), RMO LLP, Managing Partner
• Benazeer "Benny" Roshan, Partner, Greenberg Glusker
• Ronson J. Shamoun '98 (BA), '02 (JD), '03 (LLM), Principal and CEO, RJS LAW

12:20 p.m. - 1:15 p.m. - Luncheon

1 :`15 p.m. - 1:20 p.m. - Remarks by Jordan Marks, San Diego County Chief Deputy Assessor / Taxpayer Advocate

1:20 p.m. - 1:40 p.m. - Presentation of Richard Carpenter Excellence in Tax Award to Sharyn M. Fisk, Director, Office of Professional Responsibility, Internal Revenue Service

1:45 p.m. - 2:45 p.m. - Controversy Panel: Top 5 Mistakes Made In Tax Court Cases

• Moderator: Richard Carpenter '84 (JD), Tax Attorney, Richard Carpenter Tax Law Office, Adjunct Professor of Law, USD School of Law
• Jonathan Amitrano '11 (JD), Partner, Taylor Nelson Amitrano LLP
• Steven L. Jager, Partner, Fineman, West and Company, LLP
• Chad D. Nardiello '99 (BA), '02 (JD), Principal at Nardiello, Turanchik, LLP
• Hon. Emin Toro, Judge, United States Tax Court

2:45 p.m. - 2:50 p.m. - BREAK

2:50 p.m. - 3:50 p.m. - Government Loans Panel: IRS Cares About CARES Act Abuses: PPP, EIDL, & Other Government COVID Relief Audits/Criminal Investigations

• Co-Moderators: Sam Imandoust, Of Counsel, RJS LAW and Kaveh Imandoust, JD, MBT, CPA, RJS LAW
• Dylan M. Aste '11 (JD), Assistant United States Attorney, U.S. Attorney's Office, Southern District of California
• Joseph Orabona, Senior Litigation Counsel, U.S. Attorneys Office, Southern District of California
• Dennis L. Perez, Principal, Hochman Salkin Toscher Perez P.C.
• Jason Powell, Supervisory Special Agent, San Diego, Group 16, IRS

3 :50 p.m. - 4:00 p.m. - BREAK

4:00 p.m. - 5:30 pm. - Criminal Tax Workshop

• Moderator: Sandra R. Brown, Principal, Hochman Salkin Toscher Perez P.C.
• John D. (Don) Fort, Director of Investigations, Kostelanetz LLP
• Hon. Allison H. Goddard '00 (JD), Magistrate Judge, U.S. District Court, Southern District of California
• Daniel C. Silva, Shareholder, Buchalter
• Victor Song, COO, Integritas3

5:30 p.m. - 7:00 p.m. - Networking Reception with Hosted Bar and Hors d'Oeuvres at the Garden of the Sea, The Joan B. Kroc Institute for Peace & Justice.

The University of San Diego School of Law is a State Bar of California-approved MCLE provider.

RJS LAW is a registered Continuing Education provider with the IRS.

Host or Publisher University of San Diego School of Law