Kwong v. United States & Other Hot IRS Issues (Free to Members)
Overview
Kwong + Loper Bright = a new fight over IRS timing rules – and a potential window for significant client relief.
Learn how the U.S. Supreme Court’s decision in Loper Bright opened the door for cases like Kwong. This session breaks down Kwong’s IRC 7508A(d) disaster relief analysis and what it means for limitations computations, refund claim timing, and potential interest and penalty abatement.
Practical takeaways include:•
- How to find COVID period interest and penalty exposure on IRS transcripts
- When protective claims -- including Form 843 -- make sense, and how to execute them cleanly
- A streamlined checklist for implementation
- Key deadlines on the horizon -- and why they matter
- Other "hot" issues raised by Kwong that practitioners should be watching now
Leader(s):
Leader Bios
Michael Goller, Shareholder & Tax Department Chair, Reinhart Boerner Van Deuren s.c.
Michael Goller is a shareholder in Reinhart’s Corporate and Tax Departments, where he served as Tax Department Chair for more than 10 years. He leverages his more than three decades of experience, accounting degree and strong relationships within the IRS and various State Departments of Revenue to be an especially effective lawyer. He assists clients with federal and state tax controversy, tax litigation and tax planning.
Michael’s clients vary from large public corporations to mid-sized, private businesses. He’s a self-described “tax geek who litigates,” pairing his outgoing personality with extensive, detailed knowledge and a dedicated work ethic. He represents clients involved in complex disputes with the IRS, the U.S. Department of Justice and various other authorities and has an impressive track record of favorable settlements.
He is the co-author of Federal Tax Practice and Procedure (CCH). Michael enjoys sharing his expertise through writing and speaking engagements on a variety of tax controversy, litigation and planning topics. He is a longtime faculty member at the University of Wisconsin-Milwaukee’s Lubar School of Business and teaches Tax Practice and Procedure in the Graduate Tax Program.
Outside the office, he enjoys cooking haute cuisine, having taken cooking classes in both Italy and France. In fact, over the years, Michael has raised significant funds for a variety of charities by auctioning his services as a chef. He spends time with his wife and daughter, plays golf and loves to travel.
Practices
Tax | Litigation | Corporate Law
Services
Federal Tax Controversy and Litigation | Federal Tax Planning | State and Local Tax (SALT) | Trust, Estate and Fiduciary Litigation | Tax-Exempt Organization
Non-Member Price $25.00
Member Price $0.00