Getting Facts Into a Remote Proceeding Tax Court Case

Level: Beginner
Runtime: 92 minutes
Recorded Date: April 21, 2021
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  • What is the Record Rule?
  • The Importance of the Administrative Record
  • The Record Rule in Collection Due Process Cases
  • Building the Record
  • Challenging the Record
  • Whistleblowers
  • Innocent Spouse
  • Results of Success
  • Conclusion
Runtime: 1 hour, 32 minutes
Recorded: April 21, 2021


This expert panel will discuss procedures that may have changed in remote US Tax Court proceedings for obtaining facts & evidence for cases. Discussion will include the Tax Court's somewhat unique stipulation process and the panel will also discuss both formal and informal discovery tools – including subpoenas - that tax practitioners need to know when representing their clients before the Tax Court. When (and how) can a practitioner rely on the more formal discovery mechanisms?

This program was recorded on April 21st, 2021.

Provided By

American Bar Association


Rachel L. Rollins

Senior Attorney
U.S. Department of the Treasury

Rachel L. Rollins is a Senior Attorney at the Internal Revenue Service. She earned her JD at the University of Virginia School of Law in 2011.

James G. Steele, III

Morgan, Lewis & Bockius LLP

James Steele concentrates his practice on federal tax controversy, representing clients before the US Tax Court, the US Court of Federal Claims, and US district and appellate courts. James also represents clients before the Internal Revenue Service, assisting with IRS examinations, appeals, ruling requests, and other administrative proceedings. He advises clients on a variety of United States and international tax matters. Before joining Morgan Lewis, James served as law clerk to Judge Carolyn P. Chiechi of the United States Tax Court.

George Willis

Professor & Director of the Tax Clinic
Chapman University School of Law

Professor George Willis is the Director of the Tax Law Clinic and is also the Administrator of the law school's Graduate Tax Programs including the LL.M. in Taxation.

Professor Willis earned his Bachelor of Science degree in Finance from California State University, Long Beach and earned his Juris Doctor degree from the Chapman University Fowler School of Law. He has achieved numerous advanced certifications in varied areas of development. Professor Willis primarily teaches tax law clinic courses in which students represent taxpayers on a pro bono basis before the IRS and in the U.S. Tax Court. He joined Chapman in 1999 after working in practice as a Tax, Business and Estate Planning attorney serving individuals and close corporations.

Before opening his practice, Professor Willis worked for the Internal Revenue Service, Estate and Gift Tax Division and at the First American Corporation under their general counsel. Prior to his legal career he was a Senior Engineer, working for nearly a decade with the Northrop- Grumman Corporation concentrating in special projects at their Advanced Systems (later called B-2) Division and other locations. He is a member of the American Bar Association section for Taxation and the Probate & Real Property Section. As part of the Tax Section, he is actively involved with the committee for Low Income Taxpayers and serves as the moderator of their listserv. He is also a member of the California Bar Association Taxation section and the Orange County Bar Association sections on Estate Planning, Probate & Trusts, and Taxation. He has served as panelist and moderator at numerous American Bar Association (ABA) and Internal Revenue Service (IRS) symposia. He also performs pro bono work as a member of the 9th Circuit Court of Appeals Pro Bono Panel, and as an attorney-volunteer for the Public Law Center in Orange County, California.

Hon. Diana L. Leyden

Adjunct Professor of Law & Special Trial Judge (U.S. Tax Court)
Georgetown Law

Professor Leyden is Special Trial Judge with the United States Tax Court. Judge Leyden started in her current position in June, 2016.

Prior to becoming a Special Trial Judge, Judge Leyden served as the first Taxpayer Advocate for the New York City Department of Finance, creating that position and issuing the first Annual Report of the NYC Taxpayer Advocate in May 2016. Prior to that, Judge Leyden was the Director and Clinical Professor for the UConn Law School Tax Clinic, a low-income taxpayer clinic. She created and ran that clinic for 16 years. Judge Leyden was a former Chair of the ABA Low Income Taxpayer Clinic and the recipient of the ABA Janet Spragens Pro Bono Award in 2005 She has been a frequent speaker on tax practice and procedure and ethics. J

udge Leyden also served as a Law Clerk to the Hon. Herbert Chabot, U.S. Tax Court, practiced in private law practice, and worked in two state departments of revenue. She is the author of Advocating for Low Income Taxpayers: A Clinical Studies Casebook and Practice Handboodk (5th ed. 2015) and a contributing author to Effectively Representing Your Client Before the IRS (6th ed.).

Judge Leyden is a graduate of the Georgetown University Law Center LL.M. program.

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