"From Audit Through Appeals to Litigation: What You Need to Know Now"
Ballroom C
7:15-9:00AM
Using a backdrop of the hottest issues for closely-held companies and their owners, we will focus on the dangers you and your client face - and more importantly, the strategic opportunities for getting the best possible result. We will cover Section 7491 burden of proof, document production and defenses, the ability of the POA to handle interviews under Section 7521(c), the choice of going to Appeals by way of protest vs. petition, Appeals letter briefs, choice of trial forum and circuit, deciding how detailed your petition should be, the use of experts, and, time permitting, trial and briefing.