17th Annual NYU Tax Controversy Forum

Kostelanetz LLP, NYU School of Professional Studies
Seminar
June 26 - 27, 2025
The Westin New York at Times Square
270 West 43rd Street
New York, NY 10036

Tax attorneys Joshua Odintz, James Dawson, Amish Shah and Christopher Rizek will be participating in the 17th Annual Tax Controversy Forum, hosted by Kostelanetz LLP and the NYU School of Professional Studies. This forum brings together industry professionals, government officials and leading private practitioners to discuss a broad spectrum of topics related to federal tax audits, appeals and litigation. The sessions will cover procedural and substantive matters, international tax issues, ethical considerations, current enforcement initiatives, sensitive audits, civil and criminal tax penalties, and more.

Session Times and Topics

What's Next for the IRA? A Budget and Policy Perspective
June 26, 2025 | 8:30 – 9:30 a.m.

Mr. Odintz will examine how leadership turnover at the IRS, coupled with staff and funding reductions, will affect the agency's enforcement capabilities and priorities. He will provide insight into what these changes will mean for the future of tax administration, tax controversy and tax policy.

Partnership Audits and Litigation Under the BBA
June 26, 2025 | 2:10 – 3:00 p.m.

Mr. Dawson will moderate a discussion about the centralized partnership audit regime under the Bipartisan Budget Act (BBA) and recent partnership audit trends. The panel will dive into what notices to expect from the IRS, actions to take during the audit, methods to challenge proposed adjustments and impacts on individual partners.

Securing Relief from Late Elections, 9100 and Beyond
June 26, 2025 | 3:20 – 4:10 p.m.

Mr. Rizek will join a panel discussing two categories of missed election relief for taxpayers: automatic and nonautomatic relief. He will explain which missed elections qualify for Section 9100 relief and offer practical guidance on preparing and submitting requests for relief.

Substantiating and Defending Audits of IRA Clean Energy Credits
June 26, 2025 | 4:30 – 5:30 p.m.

Mr. Shah's presentation will address topics emerging in Inflation Reduction Act (IRA) clean energy tax credit audits and outline strategies that taxpayers and practitioners can use to prepare for and navigate these audits effectively.

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