Orange Beach AL : 2019 Annual Meeting & Education Conference

Jul 03, 2019 04:00pm -
Jul 08, 2019 08:00am

Event Type: Annual Meeting
Category: Fall Meeting

Speaker Information



Offering 15 Hours of CPE/CLE/MCLE and on a 50-minute schedule or 12.5 Hours of CPE/CLE/MCLE on a 60-minute schedule.

We are finalizing the program now, please check back as we add on more dynamic sessions.  Below please find the latest education schedule.
Subject to Change

Thursday, July 4, 2019
IRS E-Services & Transcript Analysis For Tax Professionals
Roger NemethEA, NTPI Fellow

This class will discuss how a tax professional can leverage the features of the IRS online Transcript Delivery System to help them better serve their clients.  The course will cover everything from how to sign up through the Transcript Delivery System and how to use the transcripts to better serve tax and tax resolution clients including how to detect IRS Audits up to six months in advance.

NASBA approved for 1.5 CPE hours in Tax; 1.5 (M) CLE

Federal Tax Developments 2019​
David De Jong, LL.M, CPA
Stein Sperling Bennett De Jong Driscoll PC

This session will cover the most important federal tax developments of the last 18 months including new laws, regulations, cases and rulings.  While many changes in the “body of tax law” are well publicized, the program will look to inform the attendee of those developments as well as others which may not have received the same initial attention.

NASBA approved for 2.0 CPE hours in Tax; 2.0 (M) CLE

New Partnership Audit Rules
Johnny Lyle, Esq.

Adams and Reese

The session will discuss the new partnership audit rules that went into effect on January 1, 2018. In addition to a discussion of the basics of the new rules, the session will focus on the impact of the new partnership audit rules on existing and new partnership, limited partnership and limited liability company agreements.

NASBA approved for 1.5 CPE hours in Tax; 1.5 (M) CLE

Friday, July 5, 2019
Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices
Michael Sardar, Esq., LLM,
Kostelanetz & Fink, LLP

In the event of a loss of client records or due to poor record keeping, a paid preparer may need to help his client reconstruct the records and/or make estimates. This session will cover tips and ideas on how to handle such issues from tax-return preparation through audit and will include a review of the Schedule C Form, common Schedule C pitfalls, and the best practices for how the tax return preparer and client can utilize estimates and reconstructions in these situations.  The session will address the Cohan rule and the AICPA Statement on Standards with respect to the use of estimates.​

NASBA approved for 1.5 CPE hours in Tax; 1.5 (M) CLE

IRS Voluntary Disclosures: Past, Present, And Future
Caroline Ciraolo, Esq. and Michael Sardar, ​Kostelanetz & Fink, LLP
Moderator: Daniel Rosefelt, Esq., CPA, Daniel Rosefelt & Associates, LLC
The IRS has offered noncompliant taxpayers a path to come into compliance for decades. First, under the Internal Revenue Manual voluntary disclosure practice, and then under the historic Offshore Voluntary Disclosure Programs. In November 2018, the IRS announced new provisions that will apply to all future domestic and offshore voluntary disclosures. Since then, practitioners have been debating the new voluntary disclosure practice and its impact on clients, and taxpayers are wondering if this is the best approach to resolve outstanding issues. The panelists will outline the new framework and engage in a spirited discussion regarding various open issues and best practices.

NASBA approved for 1.5 CPE hours in Tax; 1.5 (M) CLE

What’s New in Federal Tax Enforcement?
Caroline Ciraolo, Esq. 
Kostelanetz & Fink, LLP
Caroline Ciraolo, partner with Kostelanetz & Fink, LLP in Washington, D.C. and former Acting Assistant Attorney General of the Tax Division, U.S. Department of Justice, will discuss current priorities of the IRS and the Tax Division, domestic and international audit campaigns, current staffing and budget issues, new investigative units, and recent enforcement statistics.

NASBA approved for 1.5 CPE hours in Tax; 1.5 (M) CLE

Opportunity Zones

Brian Smithweck, J.D., LL.M
Adams and Reese
In this session find out the purpose behind Opportunity Zones  and explore where they are located, who and how  one qualifies, the structuring options, and tax benefits.​

NASBA approved for 1.5 CPE hours in Specialized Knowledge; 1.5 (M) CLE


Saturday, July 6, 2019 
The New Reality of US Sales Tax: Economic Nexus and Marketplace Facilitator Statutes

James Sutton, Esq., CPA
Moffa, Sutton & Donnini, P.A.

The session will cover the most important federal tax developments of the last 18 months including new laws, regulations, cases and rulings.  While many changes in the “body of tax law” are well publicized, the program will look to inform the attendee of those developments as well as others which may not have received the same initial attention.

NASBA approved for 1.5 CPE hours in Tax; 1.5  (M) CLE

9:15 - 10:55am
Discharging Tax Debts In
Daniel Rosefelt, Esq., CPA
Daniel Rosefelt & Associates, LLC

Many tax professionals are unaware that income tax debts can be discharged in many chapter 7 bankruptcy cases.  Additionally, many bankruptcy attorneys are unaware that high-income individuals with significant tax debts are often “non-consumer” bankruptcy cases and not subject to the “Means Test” and “presumption of abuse” provisions of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA).  As a result, many high-income taxpayers can receive a Chapter 7 discharge of tax debts.  This session will review the rules, case law and strategic issues of resolving significant tax debts for individuals in bankruptcy where there is no practical alternative of resolving their tax problems with the taxing authorities.

NASBA approved for 1.5 CPE hours in Bankruptcy; 1.5  (M) CLE



Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office.  Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and tax tribunals, providing related tax advice, including advice on uncertain tax positions, financial reporting, claims for refund, amended returns, voluntary disclosures, and internal investigations, and representing individuals and institutions in criminal tax investigations and prosecutions.

During her tenure with the Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections.  Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. account holders, and imposed and collected more than $1.36 billion in penalties, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statutes and regulations. 

Prior to joining the Department, Caroline was Chair of the Tax Controversy and Litigation practice group of a regional firm in Baltimore, Maryland, where she represented individuals and businesses in all phases of state and federal civil tax controversies and criminal tax investigations and prosecutions. She has appeared before the IRS, the Comptroller of Maryland and the D.C. Office of Tax and Revenue, the Maryland Tax Court, the U.S. Tax Court, U.S. District Courts, the Maryland circuit and appellate courts and the U.S. Court of Appeals for the Fourth and Federal Circuits.

Caroline is a Fellow and Regent of the American College of Tax Counsel, a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, and served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade in Maryland.  She has been recognized by Chambers, Benchmark, Best Lawyers in America, Super Lawyers (Top 10 Attorneys in Maryland, and cover story in 2013), Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014), and The Daily Record’s Top 100 Women Circle of Excellence.  In January, 2017, Caroline was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award, the highest honor that can be conferred by that office.

Caroline served as an Attorney Advisor for the Honorable Stanley J. Goldberg of the U.S. Tax Court from 1994 to 1996.

David S. De Jong, LLM, CPA, practices law with the Rockville, Maryland, firm of Stein Sperling Bennett De Jong Driscoll PC, concentrating his practice in tax planning and controversy, estate planning, business transactions and valuations. An adjunct professor for over 25 years at five universities, he currently teaches part-time at the Washington and Lee University School of Law. For 16 years he coauthored J. K. Lasser’s annual tax planning book. Mr. De Jong has litigated cases in each federal tax forum and has testified as an expert witness over 50 times in court, arbitrations and before disciplinary panels. Active in many professional groups, Mr. De Jong is a Past President of the American Association of Attorney-Certified Public Accountants. In 2006, he was listed as one of the Top 100 Attorneys in the United States by Worth magazine; he has received additional accolades from Washingtonian Magazine, Washington Smart CEO, Best Lawyers in America, Super Lawyers and CPA Magazine. Mr. De Jong received his BA from the University of Maryland, his JD from Washington and Lee University, and his LLM in Taxation from Georgetown University.



John (“Johnny”) F. Lyle, III is an attorney with the law firm of Lyle Johnson LLC in Fairhope Alabama. Johnny practices law in the areas of corporate, partnership and limited liability company planning, estate planning, probate, trust and estates, domestic and international tax planning, tax controversies, transactions, mergers and acquisitions, timber, public finance, economic development and tax credits, and franchise law representing businesses, individuals and families. 

Johnny received B.A. and M.A. degrees in Economics and a J. D. from the University of Alabama.  He received his LL.M. in Taxation from Emory University and is admitted to practice law in Alabama, Florida and Georgia. 

Johnny was a member of the Alabama Law Institute committees that prepared the Alabama Revised Uniform Partnership Act of 1997, the 1998 revision to the Alabama Limited Liability Company Act, the 2014 changes to the Conversions and Mergers section of the General Provisions of the Alabama Business and Nonprofit Entities Code, and the Revised Alabama Limited Liability Company Law of 2014. He is a member of the standing Alabama Law Institute committee on Business Entities. He is Vice-Chair of the LLCs, Partnerships and Unincorporated Business Entities Committee (“LPUE”) of the Business Law Section of the American Bar Association, chairman of the LLCs in Estate Planning subcommittee, and is working on LPUE subcommittees creating a Model Series LLC Agreement and a Model Family Limited Liability Limited Partnership Agreement.

Johnny is a member of the Board of Directors of the Federal Tax Clinic, the American Institute of Federal Taxation, the American Forest Landowners, Inc. and the Estate Planning Council of Mobile (past president). He is also a member of the Tax Section of the Alabama Bar Association (past chairman).

He is a frequent speaker in the areas of tax planning, estate planning, business planning, family businesses, and on corporate, partnership, and limited liability company issues.


Roger Nemeth is the President, Enrolled Agent, NTPI Fellow. He has been doing taxes since 2006. During that time he has been the General Manager for a large franchise in Atlanta as well as a Technology Manager for several tax franchises.  Roger obtained his Enrolled Agent Status in 2011.  Roger is also an NTPI Fellow. Prior to getting into taxes Roger worked as a Deputy Sheriff in Leon County Florida for 8 years. Roger was injured in the line of duty and moved into the tax field. He was awarded the Medal of Valor and Purple Heart by the Florida Sheriff's Association.


Daniel S. Rosefelt is the principal of Daniel Rosefelt & Associates, LLC, with offices in Bethesda Maryland (main office) and in Saint Petersburg Florida.  Mr. Rosefelt has been a tax attorney for over 26 years and a Certified Public Accountant for over 35 years. His practice focus is tax controversy and represents individuals and businesses with significant tax debts, unfiled tax returns, under-reported income, domestic/offshore voluntary disclosures, egg-shell audits, employment tax issues and criminal tax investigations.  He has extensive experience in resolving significant tax debts for high income clients by discharging taxes in bankruptcy.  He has litigated cases in the U.S. Tax Court, U.S. Court of Federal Claims, U.S. Bankruptcy Court and various state courts.  Mr. Rosefelt is the current Chair of the AAA-CPA Education Committee and a member of its Board of Directors.  He has also served as an Adjunct Professor of Tax Law and an Adjunct Professor of Legal Research & Writing at Stetson University College of Law, where he graduated cum laude, was a Legal Research and Writing Teaching Fellow and published member of Law Review. He holds a Bachelor of Business Administration in Accounting from the University of Wisconsin-Madison and is a licensed Certified Public Accountant in Florida and Maryland. Mr. Rosefelt is also a member of the Maryland, Washington, D.C. and Florida Bars.


Michael Sardar joined Kostelanetz & Fink, LLP in 2009. Sardar's practice focuses on all stages of civil and criminal tax controversies. H, e represents taxpayers before the Internal Revenue Service, state tax authorities, the Department of Justice, and local prosecutors. Sardar has vast experience representing clients making voluntary disclosures of unreported income to the Internal Revenue Service and state tax authorities.


Sardar has successfully represented scores of clients with unreported foreign assets who have repatriated over half a billion dollars of offshore assets through the IRS's Offshore Voluntary· Disclosure Program and the Streamlined Compliance Procedures. Sardar also represents taxpayers in New York State and City residency audits and investigations. Sardar is the Vice-Chair of the New York County Lawyers' Association (NYC LA) Taxation Committee, member of the Committee on Personal Income Taxation, New York City Bar Association, as well as Co-Chair of the Sub-Committee on Offshore Enforcement of the ABA Committee on Civil and Criminal Tax Penalties. Michael lectures frequently on tax controversy issues including foreign asset reporting.


Prior to joining Kostelanetz & Fink, Sardar was a tax associate in the New York office of Heller Ehrman, LLP, where his practice focused on federal and state transactional tax matters. While at Heller Ehrman, Sardar also advised many nonprofit organizations on federal and state tax issues including general tax exemption and Unrelated Business Income Tax (UBIT).  Sardar received his B.B.A., summa cum laude, from Baruch College in 2004, and his J.D. in 2007 from Cornell University Law School.


Brian Smithweck, J.D., LL.M., Adams and Reese, practices in the areas of corporate, partnership and limited liability company planning, estate planning, probate, trusts and estates, mergers and acquisitions, tax planning and tax controversies. He represents businesses, individuals and families.

Brian received his Master of Laws in Taxation from the University of Florida and is admitted to practice law in Alabama, Florida and Georgia. He is a member of the Board of Directors of the Estate Planning Council of Mobile, Inc. and is a frequent speaker on the topics of estate planning, business planning, family businesses and corporate, partnership and limited liability company issues.


James Sutton, Moffa, Sutton & Donnini, PA, serves as the State and Local Tax Chairman for the AAA-CPA.  He was the lead author of an Amicus Curiae Brief filed on behalf of the AAA-CPA in the SD v Wayfair case and attended oral arguments before the Court.  Sutton also testified before the House Judiciary Committee on “Alternatives to the Marketplace Fairness Act.” He taught state and local tax for over ten years at Stetson University College of Law and Boston University’s LLM in Taxation program.  With an almost exclusive focus on Florida Sales and Use Tax and over 100 years of cumulative experience in sales and use tax law in his firm, Sutton can provide in-depth, off the cuff discussions on Florida sales and use tax law in virtually every industry in Florida. Sutton’s firm handles audits, protests, petitions for reconsideration, litigation, appellate litigation, voluntary disclosures, collections, and criminal defense - all in the realm of sales and use tax.  Sutton speaks regularly on various sales tax topics for the FICPA, NBI, Lorman Education, and many other organizations.