Frank J. Jackson and Michael J. Scarduzio were speakers at the American Bar Association (ABA) Criminal Tax Fraud & Tax Controversy 2023 conference on December 7–9 in Las Vegas. The 40th Annual National Institute on Criminal Tax Fraud and the 13th Annual National Institute on Tax Controversy is the yearly gathering of the criminal tax controversy and criminal tax defense bar. This program brings together high-level government representatives, judges, corporate counsel and private practitioners engaged in all aspects of tax controversy, tax litigation and criminal tax prosecutions and defense.

On December 7, Michael was a panelist on the “Civil Workshop – Nuts and Bolds of Tax Controversy Practice” session, which discussed discovery tools in tax controversy cases, best practices for discovery motions and hearings and trial procedures in Tax Court including witness testimony, asserting privileges, contempt powers and interlocutory appeals.

On December 8, Frank moderated the panel, “Changing the Rules, We Thought We Knew: From Tax Court Jurisdiction Through Penalty Determinations,” which discussed the current state of evolving standards in tax controversy practice, key developments affecting practice before the Tax Court, significant issues in recent proceedings and pending cases to watch.