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Hot Topic: ERC - Separating Fact from Fiction as IRS Disputes Get Underway

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Hot Topic: ERC - Separating Fact from Fiction as IRS Disputes Get Underway
IRS Program #:
CTEC #: 6257-CE-0292
CE: 2 IRS & 2 CTEC credits
Speaker: Hale E. Sheppard (B.S., M.A., J.D., LL.M. and LL.M.T.)

This tax incentive has all the elements necessary to ignite a major battle:  A complex law, multiple sources of administrative guidance, rules with retroactive effect, delays and oversights, reports criticizing IRS errors, large numbers of eligible taxpayers, companies advertising questionable credit claims, open assessment periods, and repeated IRS warnings of serious civil and criminal enforcement.  This presentation explains the rules, common misconceptions, positions by taxpayers, attacks by the IRS, and main issues arising in the many ERC battles getting underway.


  • Hale Sheppard, B.S., M.A., J.D., LL.M. and LL.M.T.

    Hale E. Sheppard is a shareholder in the Tax Controversy & Litigation Section of Chamberlain Hrdlicka and chair of the International Tax Section. Hale defends individuals and businesses during tax audits, tax administrative appeals, and Tax Court litigation.

    Recent Cases:
    Hale has handled over 100 cases with the U.S. Tax Court. His reported cases include Landow v. Commissioner, T.C. Memo 2011-177, Virginia Historic Tax Credit Fund v.Commissioner, T.C. Memo 2009-295, rev’d 639 F.3d 129 (4th Cir. 2011), Heartland AutomotiveEnterprises, Inc. v. United States, 10 AFTR 2d 2009-2406 (M.D. Ga 2009), Topping v. Commissioner, T.C. Memo 2007-92, and Vines v. Commissioner, 126 T.C. 279.

    Recent Rulings:
    In addition to resolving issues through Tax Court litigation, Hale has obtained dozens of favorable determinations from the IRS National Office on procedural, tax, and international issues. Among these are Private Letter Rulings 101685-19, 107887-17, 107272-17, 107273-17, 101616-17, 137767-16, 131079-14, 201408003, 201338014, 201309001, 201308003, 201242004, 201210009, 201131017, 201002030 and 200751012.

    Recognitions: During his studies, Hale received several awards for academic excellence, including the prestigious Harry S. Truman Foundation Scholarship, Janice Dawson Quinn Tax Scholarship, Tinker Foundation Scholarship, and Senator James B. Pearson International Fellowship. Hale also served as a graduate editor of the Florida Tax Review and member of the Kansas Journal of Law & Public Policy. Hale has been recognized as a leader in tax litigation for many years by Chambers USA and other respected organizations. He has also been inducted into the American College of Tax Counsel.

    Activities and Affiliations: Hale has held leadership positions in many professional and civic organizations, including: (i) Journal of Taxation, former Editorial Board Member and tax columnist, (ii) IRS-Practitioner Liaison Committee, state bar representative, (iii) Journal of Tax Practice & Procedure, Editorial Board Member, (iv) Georgia Bar Tax Section, former President, (v) Georgia Bar Journal, former Editorial Board Member, (vi) GSU Low-Income Taxpayer Clinic, Advisory Committee Member, and (vii) Atlanta Bar Tax Section Board Member.

May 8, 2024
Wed 11:00 AM EDT

Duration 2H 0M

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