Matt Mueller To Moderate Panel At The ABA Section Of Taxation’s 2020 Midyear Tax Meeting

In the last two decades, civil injunction lawsuits initiated by the U.S. Department of Justice, Tax Division citing Section 7402 have risen significantly compared to historical data.  More recently, these suits for injunction have also included claims for disgorgement under Section 7402 and have been applied against not only fraudulent tax return preparation businesses but also against promoters of allegedly abusive tax shelters and other tax avoidance techniques.  IRS also wields various penalty provisions of the Internal Revenue Code to punish and deter promoters and preparers from skirting the law.

Matt Mueller, Guerra King shareholder and former DOJ Tax Division trial attorney, will be moderating a panel presentation sponsored by the Civil and Criminal Tax Penalties Committee of ABA’s Section of Taxation at the 2020 Midyear Meeting on February 1st in Boca Raton.   The title of the panel is “The Age of Promoter Penalties: Fighting the Good Fight.”  The panel will explore the current legal and enforcement landscape surrounding promoter penalties including a discussion of the current enforcement focus on promoters of micro-captive insurance structures, syndicated conservation easements, and other tax advantaged structures.

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