Fourth Annual USD School of Law - RJS LAW Tax Controversy Institute

This event occurred in the past

Fourth Annual USD School of Law - RJS LAW Tax Controversy Institute

This event occurred in the past

Date and Time

  • Friday, July 19, 2019 from 7:30 a.m. to 5:30 p.m.


Joan B. Kroc Institute for Peace and Justice, Theatre

5998 Alcala Park San Diego, CA 92110




This year’s USD Law – RJS Law Tax Controversy Institute will be held on July 19, 2019, in San Diego, CA. The Institute is the premier tax controversy event in San Diego. The region's top tax attorneys, CPAs, and law/business school professors will discuss topics including passthrough planning, Wayfair, ethical pitfalls to avoid in practice, and employee classification issues in California.

Don Fort, Chief of Criminal Investigation at the IRS, will kick off the conference with introductory remarks. Panelists include:

  • Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
  • Richard Carpenter, Richard Carpenter Tax Law Office
  • Sandra Brown, Principal, Hochman, Salkin, Toscher, Perez, PC
  • Martin Schainbaum, Of Counsel, RJS LAW

We’re honored to also have United States Tax Court Chief Judge Maurice B. Foley as the keynote luncheon speaker.

At the conference, we will be presenting the Richard Carpenter Award to a distinguished individual who illustrates the notable achievements of Richard Carpenter honoring his 30 years of excellence in the tax field and his continued commitment to the tax community. The award is given to individuals who personify honesty, integrity, ethics, and compassion throughout his/her careers in the field of tax controversy and have demonstrated outstanding dedication and expertise while representing taxpayers before the federal and state governments.

We are excited to announce Richard Shaw as the recipient of the 2019 Richard Carpenter Excellence in Tax Award. Mr. Shaw is a California Certified Specialist in Taxation and an attorney at Higgs Fletcher & Mack. He’s a nationally recognized business and tax lawyer and former Chair of the ABA Section of Taxation. Mr. Shaw also testifies as an expert witness and lectures nationally on business and tax issues.

The Institute will also provide phenomenal networking opportunities to meet other top practitioners, tax attorneys, CPAs, EAs, tax preparers, and students are all welcome to attend.

During the Tax Controversy Institute Evening Reception, Dean Stephen C. Ferruolo will be honoring the life, legacy, and dedication of three distinguished USD law school alumni and former members of the USD School of Law Board of Visitors.

  • US Attorney for the Southern District of California, Robert S. Brewer '75 (JD,) will serve as the keynote speaker as well as the presiding officer for the ceremony.
  • Gerald L. McMahon '64 (JD) will be remembered by Seltzer, Caplan, McMahon & Vitek partner, Andrea Myers '08 (JD)
  • Craig Higgs '69 (JD) of Higgs Fletcher & Mack will be honored by managing partner, Steven J. Cologne '84 (JD)
    Michael T. Thorsnes '68 (JD) will be celebrated by Senior Partner, John F. "Mickey" McGuire of Thorsnes Bartolotta McGuire LLP


Click here to view photos from last year’s USD School of Law - RJS LAW Tax Controversy Institute.

If you would like to make a contribution to the USD School of Law - RJS LAW Tax Controversy Institute, please click here. Thank you for your support.


Registration Information

Registration categories are listed below.

Registration Category Fee
General Registration  $395
Attorneys (1-5 years), USD Alumni $345
CPAs, Enrolled Agents, or Tax Preparers $345
Government Employees $150
Students $30
Professors FREE
Reception Only $75

Discounts are available for groups of 2 or more (must be from the same organization). Please contact


Program Schedule (updated 06-27-19)

Friday, July 19, 2019

8:15 – 8:30 a.m.

INTRODUCTORY SPEAKER: John (Don) Fort, Chief, IRS Criminal Investigation

8:30 - 8:45 a.m.

Opening Remarks: Professors Ronson J. Shamoun & Miranda Perry Fleischer, USD School of Law

8:45 – 9:45 a.m.

Tax Planning: A Year After the Tax Cuts and Job Act

  • Phillip Jelsma – Adjunct Professor of Law, USD School of Law; Partner, Crosbie Gliner Schiffman Southard
  • Ariel Jurow KleimanAssistant Professor of Law, USD School of Law
  • Miranda Perry FleischerProfessor of Law and Co-Director of Tax Programs, USD School of Law (Moderator)
  • Kirk StarkBarrall Family Professor of Tax Law and Policy, UCLA School of Law
9:50 - 10:50 a.m.

Is Wayfair, Way Fair? A look at the State and Federal Implications.

  • Frank Agostino – CEO and Founder of Agostino & Associates, P.C. (Moderator)
  • John Colvin – CEO and Founder of Colvin + Hallet
  • Jennifer Kolterman – Director, Hutchinson Bloodgood, LLP
  • Nicolas Maduros – Director, CDTFA
  • Gregory Pullman – Senior Manager, KPMG Los Angeles
10:50 – 11 a.m. BREAK
11:00 a.m. – Noon

Key Sources of Civil & Criminal International Tax Controversies

  • Paul Burns – Tax Director, CBIZ MHM, LLC
  • John Forry – Managing Director, CBIZ MHM, LLC
  • Mitch Dubick – Partner, Higgs Fletcher Mack
  • L. Reza Wrathalll – Associate, Procopio, Cory, Hargreaves & Savitch LLP
Noon – 1:35 p.m.


  • Judge Maurice Foley, Chief Judge of the United States Tax Court
    (keynote will begin at 12:30pm)
1:35 – 1:45 p.m. BREAK
1:45 – 2:45 p.m.

Ethical Pitfalls and How to Avoid Them When Representing Clients in IRS Collections and Audits. 

  • Jonathan T. Amitrano – Partner, Law Offices of A. Lavar Taylor
  • Venar Ayar – Principal, Ayar Law
  • Caroline D. Ciraolo – Partner, Kostelanetz & Fink, LLP (Moderator)
  • Dawn Harris – IRS Field Collection Manager, Internal Revenue Service
2:45 – 2:55 p.m.  BREAK
2:55 – 3:55 p.m.

Employee Classification, Is It As Easy As ABC?

  • Nuna Aguilera – EDD Audit Manager Van Nuys Office
  • Michael Dallo – Dallo Law Group
  • Richard Carpenter – Richard Carpenter Tax Law Office (Moderator)
  • Bill Hartsock – The Tax Lawyer - William D Hartsock Tax Attorney Inc.
4:00 – 5:30 p.m.

Criminal Tax Procedure Workshop: Nuts & Bolts of Criminal Tax Representation

  • Sandra Brown - Principal, Hochman Salkin Toscher & Perez, P.C.
  • Hon. Angela J. Davis-Commissioner, Los Angeles Superior Court
  • John (Don) Fort- Chief, IRS Criminal Investigation
  • Hon. Marvin J. Garbis – U.S District Court Judge, U.S. District Court of Maryland (Ret.)
  • Martin Schainbaum- Of Counsel, RJS LAW
  • Steven Toscher - Principal, Hochman Salkin Toscher & Perez, P.C. (Moderator)
5:30 –9:00 p.m.

Celebrate & Connect! A Networking Reception with hosted bar and appetizers

Keynote Speaker: Robert S. Brewer. Jr. - United States Attorney, Southern District of California


  • Continuing Education Credits
    The University of San Diego School of Law is a State Bar of California-approved MCLE provider and this event has been approved for 5.5 hours of general MCLE credit hours and 1.0 hour of Legal Ethics MCLE credit hours.

    RJS LAW is a registered Continuing Education provider with the IRS and this event has been approved for 6.0 hours of IRS CE Credits.

  • Sponors

    usd sol   


     toscher lavar taylor  


    ayar law bernal law


    michael blue     richard carpenter tax


    coastal payroll   kennedy


    city national bank    callan capital