The 36th Annual National Institute on Criminal Tax Fraud is the yearly gathering of the criminal tax defense bar combined with the Ninth Annual National Institute on Tax Controversy. This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions and defense. Michelle Ferreira, Co-Managing Shareholder, will present with a panel on "Ethical Issues When Representing the Accountant in an IRS Service Investigation." The panel will discuss ethical and strategic issues concerning when and how the accountant should be represented, and the extent to which the accountant must or should cooperate with the taxpayer. The panel will also consider the role of the accountant in a sensitive tax examination. Barbara Kaplan, our Global Tax Practice co-chair, and New York Tax practice chair will also be speaking in a session titled, "Civil Enforcement Priorities," discussing the enforcement priorities with IRS leadership and will address how to prepare.