WHAT IS HAPPENING AT THE IRS OFFICE OF CHIEF COUNSEL
As the lawyers for the IRS, attorneys in the IRS Office of Chief Counsel help interpret the tax law, provide legal support to IRS personnel, and represent the IRS in litigation. With all the recent changes in the tax law, this has become an even more challenging job than usual. This panel will outline the current initiatives and priorities in the Chief Counsel’s Office.
CHANGES AT THE IRS INDEPENDENT OFFICE OF APPEALS
The Taxpayer First Act (“TFA”) created the newly named Independent Office of Appeals. The TFA also confirmed that the right to appeal cases shall generally be available to all taxpayers and enhanced taxpayers’ ability to obtain their case files. This panel will discuss will provide an overview of what is going on in the Appeals Division and how the TFA has affected Appeals Conferences.
Michael J. Desmond is the 48th Chief Counsel of the Internal Revenue Service, where he oversees a staff of more than 2,000 employees, including approximately 1,500 attorneys. Mr. Desmond began serving as Chief Counsel on March 4, 2019, following his confirmation by the U.S. Senate on February 27, 2019. As Chief Counsel, he is also an Assistant General Counsel in the Department of the Treasury. After serving as a law clerk for the Hon. Ronald S.W. Lew in the federal district court in Los Angeles, Mr. Desmond began his legal career with the Attorney General’s Honors Program at the Tax Division of the U.S. Department of Justice.
After serving in the Tax Division, he joined McKee Nelson, LLP, where he was elected in 2004. In early 2005, Mr. Desmond joined the Office of Tax Policy at the Department of the Treasury, where he served as Tax Legislative Counsel through 2008. Following his tenure at the Treasury Department, he spent several years as a partner at Bingham McCutchen LLP in Washington, D.C., and Los Angeles, California. In January 2012, Mr. Desmond started his boutique tax firm in Santa Barbara, California, where he practiced until he was nominated Chief Counsel in 2018. Mr. Desmond has held several offices with the Section of Taxation of the American Bar Association and served as a Regent for the American College of Tax Counsel. He also served as an adjunct professor at Georgetown University School of Law. Mr. Desmond was born in Santa Monica, California, and is a graduate of the University of California, Santa Barbara, and the Catholic University of America Columbus School of Law.
Steven Toscher is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization.
Sharon Katz-Pearlman is the National Principal-in-Charge of KPMG’s Tax Dispute Resolution Network in the US. She also serves as KPMG International’s Head of Global Tax Dispute Resolution & Controversy, overseeing a network of dispute resolution specialists from KPMG’s member firms.
Sharon advises clients during all phases of the “disputes continuum”, from “predispute” (e.g. audit readiness, voluntary disclosures, pre-filing assistance) through examination, appeals and the full range of alternate dispute resolution processes. With more than 25 years of experience in the field, Sharon works with clients on all aspects of their IRS matters, dealing with a wide variety of domestic and international tax issues.
Mr. Keyso is a long time veteran of the IRS, with more than 25 years of service. During his career, he has held numerous positions within the IRS, including serving as the IRS Chief of Staff, 18 years in various positions in the IRS Office of Chief Counsel, including as Associate Chief Counsel of the Income Tax and Accounting Division. Mr. Keyso also served as Special Counsel to the Chief Counsel and as an attorney in the Procedure and Administration Division. Before coming to Washington, DC, Mr. Keyso worked as a revenue agent in the former Newark, New Jersey District, where he later served as a technical advisor to the Chief, Examination Division. Since July 2017, Mr. Keyso has been the Deputy Chief of Appeals and acting Appeals Chief.
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