Federal Tax Refund Litigation: Disputing Tax Liability, Key Issues and Pitfalls to Avoid for Tax Counsel
Navigating Procedures to Contest Income, Payroll, Estate and Gift Tax Liability, and Penalties
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Thursday, July 17, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE/CPE webinar will provide tax counsel and advisers guidance on best practices in handling federal tax refund litigation matters. The program will discuss the impact of recent tax cases, navigating administrative procedures and prerequisites for filing suit, common challenges, district court vs. Court of Federal Claims, and litigation tactics. The panel will also discuss key considerations in resolving tax refund controversies and offer practical tips in light of recent court cases.
Ms. Heron White is an associate at Asbury Law Firm who focuses her practice on federal tax controversy and litigation matters, and has experience with both civil and criminal tax controversies. She is currently enrolled in the LL.M. program in Taxation at the New York University School of Law.
Mr. Vernon is an associate at Asbury Law Firm, Tax Counsel. He focuses his practice on federal and state tax controversies, tax litigation, business tax planning, and corporate organization. Mr. Vernon was selected to the inaugural Best Lawyers Ones to Watch list for Tax Law and is a 2021-2024 Rising Star by Super Lawyers.
Taxpayers may seek recovery of taxes in court if they are not able to come to a resolution with the IRS. Federal tax refund litigation is the legal process that allows a taxpayer to recover taxes, including penalties, that have been erroneously collected by the IRS.
The IRS has been aggressively enforcing compliance with U.S. tax rules and regulations; however, in some cases, taxpayers may challenge tax assessments in court. Federal tax refund litigation can be used to contest income tax liability, payroll taxes, estate and gift taxes, and penalties. Tax counsel and advisers must understand applicable tax rules, administrative procedures, taxpayer rights, and other key items in order to effectively represent taxpayer-clients in tax refund claims.
Listen as our panel discusses federal tax litigation, prerequisites and procedures, district court vs. Court of Federal Claims, and key areas of focus for counsel and advisers.
I. Overview of the federal tax refund litigation process
II. Administrative prerequisites
III. Choice of venue; district court vs. Court of Federal Claims
IV. Filing the claim and timing requirements
V. Best practices to succeed in federal tax refund claims
The panel will discuss these and other key issues:
- Navigating the federal tax refund controversy process
- How is refund litigation distinguishable from deficiency litigation?
- What are the prerequisites prior to and during federal tax refund proceedings?
- What are the critical challenges of federal tax litigation in both district courts and Federal Claims Court?
- Challenging the assessment of penalties
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