Tax Institute San Diego | USD | RJS LAW | Tax Institutes

Our 8th Annual USD School of Law – RJS LAW Tax Controversy Institute will be held on Friday, July 28, 2023. The Institute is one of the best tax controversy events in the nation held annually in San Diego. The region’s top tax attorneys, enrolled agents (EAs), certified public accountants (CPAs), law and business school professors will discuss topics including government loan relief, and abuses, challenges in cross-border transactions, and practical and realistic solutions in International Tax, Trust, Estate Planning, and Tax matters.

“We Bring the Whole Tax and Accounting Community Together”

A Leading Educational Event for Tax Professionals

Evening reception $99
Renowned panelists discussing trending topics
General Admission – $199 includes luncheon and reception
$25 for law students & faculty to attend
Earn Continuing Education Credits
Networking reception at the beautiful Garden of the Sea

2023 Institute Will Have Two Locations:

Conference Location – Registration Starts at 7:30 a.m.
Nexus Theater, Knauss Center for Business Education

Reception Location – 5:30 p.m. – 7:00 p.m
Garden of the Sea, Joan B. Kroc Institute for Peace & Justice University of San Diego

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.

For the past 30 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.

Richard Carpenter has been an Adjunct Tax Law Professor at the University of San Diego School of Law for 30 years. He teaches both the Tax Court Litigation class as well as the Criminal Tax Fraud class. Richard has written 14 published tax law articles, some of which are the leading articles in the United States in resolving civil and criminal tax disputes. Over the past 30 years, Richard Carpenter has been dedicated to helping thousands of clients resolve their tax disputes with the IRS and the State of California, saving them millions of dollars.

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2023 Agenda

7:30 a.m. – 8:30 a.m. – Registration & Continental Breakfast

8:30 a.m. – 9:00 a.m. – Introductory Speaker & Opening Remarks – Paul Yong

Ryan Korner, Director of Field Operations at IRS: Criminal Investigation

9:00 a.m. – 10:00 a.m. – Panel 1 – Estate Planning Panel: Practical and Realistic Solutions in Trust, Estate Planning, & Tax Matters

Moderator: Brian Malloy, Of Counsel, RJS LAW
Jenny Hill Bratt, Partner, Withers Bergman LLP
Brent Wilsey, President, Wilsey Asset Management
DeEtte L. Loeffler, JD, LL.M. Taxation, Founder, DeEtte L. Loeffler, a Professional Law Corporation

10:00 a.m. – 10:10 a.m. – Ten Minute Break

10:10 a.m. – 11:10 a.m. – Panel 2 – International Tax Panel: Challenges of Cross-Border Transactions

Moderator: Andrea Cisneros Valdez, Of Counsel, RJS LAW
Mary Robberson, Partner at Robberson Schroedter
A. Lavar Taylor, Principal at Law Offices of A. Lavar Taylor, LLP
Darren Guillot, IRS Deputy Commissioner SBSE Collection & Operations Support

11:10 a.m. – 11:20 a.m. – Refreshment Break

11:20 a.m. – 12:20 p.m. – Panel 3 – Trust and Estate Litigation Panel

Moderator: Jeryll S. Cohen, Partner, Freeman Freeman & Smiley LLP
David Greco, Managing Partner, RMO LLP
Benazeer “Benny” Roshan, Partner, Greenberg Glusker
Robert “Robbie” Barton, Partner, McDermott, Will and Emery LLP

12:20 p.m. – 1:45 p.m. – Lunch and 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. – Panel 4 – Controversy Panel: Top 5 Mistakes Made in Tax Court Cases

Moderator: Richard Carpenter, Tax Attorney, Richard Carpenter Tax Law Office, Adjunct Professor of Law, USD School of Law
Jonathan Amitrano, Partner at Law Offices of A. Lavar Taylor, LLP
Judge Emin Toro, Judge at United States Tax Court
Chad Nardiello, Principal at Nardiello Turanchik, LLP
Steven L. Jager, Partner, Fineman, West and Company, LLP

2:45 p.m. – 2:50 p.m. – 5 Minute Break

2:50 p.m. – 3:50 p.m. – Panel 5 – Government Loans Panel: IRS Cares About CARES Act Abuses: PPP, EIDL, & other Government Covid Relief Audits/Criminal Investigations

Co-Moderator: Sam Imandoust, Of Counsel, RJS LAW
Co-Moderator: Kaveh Imandoust, JD, CPA, MBT, RJS LAW
Joseph Orabona, Senior Litigation Counsel, United States Attorney’s Office, Southern District of California
Jason Powell, Supervisory Special Agent, San Diego, Group 16, IRS
Dylan M. Aste, Assistant United States Attorney, U.S. Attorney’s Office, Southern District of California

3:50 p.m. – 4:00 p.m. – 10 Minute Break

4:00 p.m. – 5:30 p.m. – Panel 6 – Criminal Tax Workshop

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

5:30 p.m. – 7:00 p.m. – Networking Reception with Hosted Bar and Hors d’oeuvres at Garden of the Sea, Joan B. Kroc Institute for Peace & Justice University of San Diego

Continuing Education

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. Please check back for the number of credit hours offered.

Parking at the University of San Diego

The closest public parking is located in the West Parking Structure on campus. From Linda Vista Rd, use the West Entrance at Marion Way. Follow signs to West Parking Structure after the parking kiosk stop.

The Recipient of the Richard Carpenter Excellence in Tax Award

Sharyn M. Fisk, Director, Office of Professional Responsibility, Internal Revenue Service

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

Our tax community is full of impressive individuals, and we are proud to announce Sharyn M. Fisk, who has over 20 years of tax experience, as the recipient of the Richard Carpenter Excellence in Tax Award.

Sharyn M. Fisk was named Director of the IRS Office of Professional Responsibility (OPR) in January 2020. As Director, she is responsible for the IRS’ oversight of tax professionals who practice before the IRS as set out in Treasury Circular 230.

Before her tenure at the IRS, Sharyn was Professor of Tax at Cal Poly Pomona and Director of the University’s VITA program. Prior to teaching, Sharyn was in private practice specializing in tax controversies. As a private practitioner, Sharyn represented hundreds of individuals, businesses, and corporate taxpayers before the IRS, the Department of Justice Tax Division, federal and state courts, and state taxing authorities. These matters involved civil examinations and appeals, criminal investigations, and tax collection issues. Before becoming a private practitioner, Sharyn clerked for the Honorable Maurice Foley, Judge, U.S. Tax Court.

Sharyn has held leadership roles in several professional organizations. She served as a former Chair of the Tax Policy, Practice and Legislation Committee for the American Bar Association (ABA). She is a past Chair of the Taxation Section of the Los Angeles County Bar Association and the Taxation Section of the Beverly Hills Bar Association. In 2019, Sharyn concluded a three-year term as a member of the IRS Advisory Council (IRSAC). She chaired a task force on unenrolled return preparers on behalf of the Standards of Tax Practice Committee for the ABA Taxation Section. She is also a Fellow of the American College of Tax Counsel. Sharyn wrote and spoke extensively before national, state, and local tax professional organizations on all aspects of civil and criminal tax controversy issues and ethics in tax practice.

Sharyn earned her B.A. in Journalism from San Diego State University, her J.D. from Rutgers University, and her LL.M in taxation from the New York University School of Law.

Sharyn truly embodies the venerable qualities that the Richard Carpenter Excellence in Tax Award celebrates, and we are proud to honor Sharyn and the indelible mark she has made in our tax community.