Michael Desmond will co-chair the Practising Law Institute (PLI) conference "Tax Controversy 2025: Navigating the New Enforcement Landscape" on March 24, 2025.

The Inflation Reduction Act (IRA) allocated billions in long-term funding for the IRS on top of its regular annual appropriations. Much of this additional funding has been earmarked for "enforcement," broadly defined to include a range of activities intended to ensure compliance with the federal tax law, and the IRS is actively deploying this funding to hire and train new examination agents, collection officers, and attorneys. In anticipation of an expected uptick in enforcement actions, this conference will focus on strategies for anticipating potential federal tax controversy issues before they arise, assisting taxpayers in understanding the compliance and enforcement risks associated with uncertain tax reporting positions and in taking steps to mitigate those risks, and effectively resolving issues in the IRS examination and administrative appeal process.