Ryan Law’s Bryan Dotson and Brock Whalen Provide Tax Law Expertise at NASBTS 43rd Annual Meeting
January 2, 2023
This impactful event had participation from the leadership of state and local tax law sections from all over the country. The purpose of the conference was to, among other things, keep abreast of new developments in the federal, state, and local tax areas.
Bryan presented recent developments in how receipts from services are apportioned among states for purposes of state income taxes and gave practical advice on how to handle various issues that arise under the different approaches used by the states. His co-presenter was Ray Langenberg, Special Counsel for Tax Litigation for the Texas Comptroller of Public Accounts.
Brock tackled Dealing with the Enforced Collection Actions of the IRS. During this presentation, Brock discussed many topics of interest to federal tax practitioners who may represent clients facing enforced collection efforts by the IRS. Drawing upon his twelve years of experience with the IRS, Office of Chief Counsel, he gave an overview of the field collection procedures of the IRS. He also drilled into specific topics, such as what various IRS Notices mean about the status of outstanding federal tax liability and ways of helping clients avoid IRS collection measures such as liens and levies. In addition, he provided insight into the Top Ten Federal Tax Cases of 2022. This presentation was directed towards experienced tax practitioners, and Brock provided a synopsis of several significant recent federal tax cases. The attendees expressed that the presentation was highly informative and enjoyed hearing about a variety of issues, including the failure of a taxpayer to properly establish a self-directed IRA under IRC 408; the boundary of the exclusion of personal injury settlement proceeds from taxable income under IRC 104; a recent Tax Court opinion concerning the strict statutory requirements for supporting non-cash charitable contributions under IRC 170; and the latest on the U.S. Court of Appeals circuit split concerning requirement for IRS to establish the managerial approval of penalties under IRC 6751(b).
The National Association of State Bar Tax Sections (NASBTS) is an association that provides a forum for communication and education among the Tax Law Sections of State and Local Bar Associations. Through participation in the Association, the leadership of State and Local Tax Law Sections get to know each other, exchange ideas, and keep abreast of new developments in the federal, state, and local tax areas.
Each year, the Association sponsors a conference held in late Fall. Historically, the conference has alternated between San Francisco and Washington, D.C. This is the second year NASBTS has been chosen to host the conference in another member state – Texas.
Outstanding speakers and recognized leaders in the estate planning, federal, state, and local tax fields discuss current tax issues. The leadership of State Bar Tax Sections participates in round table discussions with their peers from other states on practical subjects related to the operation of Tax Law Sections.
In addition, the Association is affiliated with the American Bar Association. The Association provides liaison services between the ABA and State Bar Tax Law Sections throughout the year. It is instrumental in obtaining and disseminating valuable information to the ABA and the State Bars.