The Frances D. Sheehy Memorial Advanced Tax Procedure Seminar

5th May 2017  08:20 AM - 05:20 PM (GMT-04:00) America/New_York

Frances Diane Sheehy, a former Chair of the Tax Section, was a frequent speaker and author on tax procedure matters, especially in the area of bankruptcy. She passed away January 26, 2017 after an extended battle with cancer. Fran earned her J.D. from the University of Arizona in 1987 where she was editor of the Law Review. After graduation, she was an attorney with the IRS Office of Chief Counsel in Miami, FL and became a Special Assistant U.S. Attorney litigating tax and bankruptcy cases.  She moved to private practice in 1992; first as a partner with tax lawyers and then struck out on her own. Fran had a formidable intellect and a genuine love of people that enabled her to make lasting friendships wherever she went. Blessed with many gifts of mind and person, Fran was even more notable for her generosity and irrepressible “dry” sense of humor. Most of all, Fran was an amazing friend and colleague. 

One Location: Friday, May 5, 2017
The Breakers Palm Beach, 1 South County Road
Palm Beach, Florida 33480
Phone: (561) 655-6611




(Max. Credit: 10.0 hours)

General: 10.0 hours • Ethics: 1.0 hour




(Max. Credit: 10.0 hours)

Tax Law: 10.0 hours


Please call  850-561-5831 for assistance with registration and ordering.


A block of rooms has been reserved at the rate of $335 per night (single and double occupancy). To make your reservations through the reservation link:

Reservations must be made by April 12, 2017 to assure the group rate and availability.


7:30 a.m. - 8:20 a.m.
Nuts and Bolts of Tax Procedure

This “bonus” session, included in the registration fee, is highly recommended for new tax attorneys or practitioners who want to be up-to-speed on tax procedure basics. This segment will review subjects such as, commonly-used acronyms, statutes of limitation, assessment procedures, common penalties, collection alternatives, collection due process hearings, and refund statutes. The session will help attendees get the most out of the advanced subjects covered the rest of the day.

Christin Bucci, Esq., Bucci Law Offices, Fort Lauderdale
Karen J. Lapekas, Esq., Lapekas Law, P.A. Miami


7:30 a.m. – 8:30 a.m.     Registration/Breakfast

8:40 a.m. - 8:50 a.m.     Introduction

8:50 a.m. - 9:40 a.m.
Less Common Internal Revenue Code Penalties
Michael A. Lampert, Law Offices of Michael A. Lampert, P.A., West Palm Beach

9:40 a.m. - 10:30 a.m.
Employment Tax Enforcement
Mae F. Butler, Group Manager, Internal Revenue Service Employment Tax, Maitland
Marissa R. Lenius, Internal Revenue Service Tax Exempt & Government Entities Counsel, Jacksonville
Harris L. Bonnette, Jr., 
Fisher, Tousey, Leas & Ball, P.A., Jacksonville

10:30 a.m. - 10:40 a.m.     Break

10:45 a.m. - 10:50 a.m.
Participating in the U.S. Tax Court Calendar Pro-Bono Program
Karen J. Lapekas, Esq., Miami

10:50 a.m. - 11:40 a.m.
Tax Enforcement, Settlement Procedures, and the Division of Authority
Angelo Frattarelli, 
Department of Justice Assistant Chief Tax Division, Civil Trial Section, Southern Region, Washington, D.C.
Brian Harris, Akerman LLP, Tampa 

11:40 a.m. - 11:45 a.m.
Pro Bono IRS Representation (referrals from Low Income Tax Clinics)
Michael Bacigalupi, Director, Low Income Taxpayer Clinic, Legal Aid Society of Palm Beach County, West Palm Beach

11:45 a.m. to 12:35 p.m.
A View from the Bench: A Conversation with U.S. Tax Court Judge Juan Vasquez
Judge Juan Vasquez, Washington, DC

Facilitator: Mitchell I. Horowitz, Buchanan Ingersoll & Rooney, P.C., Tampa 

12:35 p.m. to 1:00 p.m.     Lunch-and-Learn (Included in Registration)

1:00 p.m. to 2:20 p.m.
Offshore Tax Compliance Issues (from a Tax Controversy Perspective)
Ian M. Comisky, Fox Rothschild, LLP, Philadelphia, PA
Larry R. Kemm, Carlton Fields, Jorden Burt, LLP, Tampa
Caroline Ciraolo, former Principal Deputy Assistant Attorney General, Tax Division, Department of Justice, Washington, D.C.
John D. (Don) Fort, Deputy Chief, Internal Revenue Service Criminal Investigation, Washington, D.C.

2:20 p.m. to 2:35 p.m.     Break

2:35 p.m. - 2:40 p.m.
Participating in “Tax Court Settlement Day” as a Pro Bono Tax Attorney
Michael Bacigalupi, Director, Low Income Taxpayer Clinic, Legal Aid Society of Palm Beach County, West Palm Beach

2:40 p.m. - 3:30 p.m.
Determining (and maintaining!) Dischargeable Taxes in Bankruptcy and Pre-Bankruptcy Tax Planning Considerations
Larry Heinkel, Heinkel Tax Law Group, PL, Saint Petersburg

3:30 p.m. to 3:40 p.m.     Break

3:40 p.m. - 4:30 p.m.
So this is Privileged…Right?
Caroline Ciraolo, 
former Principal Deputy Assistant Attorney General, Tax Division, Department of Justice, Washington, D.C.
Jeffrey Neiman, Marcus Neiman & Rashbaum LLP, Fort Lauderdale
Jared Dwyer, Greenberg Traurig, LLP, Miami

4:30 p.m. - 5:20 p.m.
OPR: From Referral to Ultimate Resolution
Steve Whitlock, 
Director, Office of Professional Responsibility, Washington, D.C.
Facilitator: Mitchell I. Horowitz, Tampa

5:30 p.m. - 7:00 p.m.
Reception (Included in Registration)