Attorneys, business executives, and management professionals involved in tax and employment law and policy.
On January 11, 2011, the Supreme Court issued its decision in Mayo Foundation v. United States, No. 09-837. In addition to resolving a specific tax controversy about whether medical residents are exempt from Federal Insurance Contributions Act (FICA) taxation, the Court provided important guidance on the general principles for determining when courts must defer to Treasury Regulations. The Court's determination that "Chevron deference" principles should apply departs from the principles that many courts and tax lawyers have long followed and will make it more difficult for taxpayers in the future to challenge IRS positions embodied in Treasury Regulations.
In this one-hour TeleBriefing, our esteemed panel of experts will address the implications of the Mayo decision, the new questions that it raises about the scope of Chevron deference in the tax area, and the impact the decision is likely to have on future litigation and the regulatory and administrative guidance process.
Introduction & Overview
Alan I. Horowitz, Esq., Moderator
Miller & Chevalier Chtd / Washington, DC
Implications for Taxpayers and Their Counsel
Emily A. Parker, Esq.
Thompson & Knight LLP / Dallas, TX
Department of Justice Perspective
Gilbert S. Rothenberg, Esq., Chief of the Appellate Section and Acting Deputy Assistant Attorney General
U.S. Department of Justice / Washington, DC
$125 to dial in
$175 to dial in and receive continuing education credit
$50 for each additional person on the line who wishes to receive credit
Financial aid is available to those who qualify. Contact our office for more information.
You may substitute another person at any time. If you are unable to join the call, you can download the audio and materials later or we'll send you an audio CD and written materials for an additional $10.
This TeleBriefing qualifies for 1.0 Washington CLE credit. We will apply for CLE credits in the following states: AK, AL, AZ, AR, BC, CA, GA, IL, IN, LA, ME, MO, MS, NC, ND, NM, NV, NY, OR, PA, RI, SC, TN, UT, VA, VT, WI, WV, WY
You can self-apply for CLE credits in: CO, FL, HI, ID, MN, MT, NE, NJ, NY, OK
CLE credits currently not available from: DE, KS, OH, TX
If you need other types of credits, please check with your accrediting organization.
The dial-in number and a link to the materials will be emailed to you the day before the TeleBriefing. All orders are processed within one business day of receipt.
You may download the entire audio and materials for $125 or obtain an audio CD and printed materials for an additional $10. Both options include the written materials. Downloads are available within 48 hours after the TeleBriefing or from the date we receive payment. We will ship a CD order via UPS ground within two weeks after the TeleBriefing or from the date we receive payment.
Alan I. Horowitz, member at Miller & Chevalier Chartered, focuses on appellate litigation, with particular experience in federal tax appeals. He has litigated cases in the U.S. Supreme Court and every federal court of appeals, and he also represents clients in litigation of legal issues in trial court. Previously, he worked in the Solicitor General's Office at the Department of Justice from 1979 to 1990, serving under four Solicitors General. During that time he argued more than 25 cases before the U.S. Supreme Court and briefed many others on a variety of topics, including constitutional, statutory, and criminal issues. From 1986 to 1990, he served as the Tax Assistant to the Solicitor General and had primary responsibility both for conducting the government's tax litigation before the U.S. Supreme Court and for overseeing the government's determinations to appeal adverse tax decisions.
Emily A. Parker, partner at Thompson & Knight LLP, represents taxpayers in IRS audits and appeals proceedings, state tax audits and hearings, and federal and state tax refund and deficiency litigation. She also advises on federal income tax and Texas tax planning, with special expertise in taxation of natural resources and partnership and corporate transactions involving the petroleum industry. Ms. Parker has represented clients in a number of precedent-setting cases that decided important industry issues and developed previously unsettled issues of tax law. During the years 2002 through 2004, she was Acting Chief Counsel and Deputy Chief Counsel for the IRS.
Gilbert S. Rothenberg, Chief of the Appellate Section of the United States Department of Justice's Tax Division, has worked in the Justice Department's Tax Division for his entire career, starting out as a line attorney in the Appellate Section (where he handled, among many others, the landmark Tufts case.) He is also currently serving as Acting Deputy Assistant Attorney General for Review and Appellate overseeing the Tax Division's Office of Review in addition to the Appellate Section. Mr. Rothenberg is an Adjunct Professor of Law at the American University Law School, where for more than 25 years he has taught courses in individual and corporate income tax.