Kostelanetz counsel
Gray Proctor presents a CLE session for myLaw titled "Tax Relief Tactics: Mastering IRS Penalties, Fines, and Interest Abatement." Gray’s session, titled "Penalty Defense: Reasonable Cause + A Few More," is the second half of the two-part CLE series co-sponsored by myLaw and the Federal Bar Association. The first session, titled “Correcting Noncompliance and IRS Penalty Relief,” is presented by Phillip J. Colasanto of Withers Bergman LLP.
In Session II, Gray focuses on reasonable cause and the major role it plays in
civil tax controversy and
white-collar defense strategies. In many cases, reasonable cause is key to receiving tax penalty mitigation from the IRS. Gray's session dives into the elements of reasonable cause defenses, including the limits of the defense, the role of disclosure and level of certainty in mitigating penalties, and considerations unique to specific penalties, from failure to file to gross valuation misstatements.
Gray also discusses landmark Supreme Court decisions such as
Loper Bright and
Jarkesy, which could affect how reasonable cause defenses are utilized going forward.
You can learn more about the webinar and register for the recorded session
here.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.
