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Tax Implications of COVID-19: Tax Collection in the Time of COVID-19

Level: Intermediate
Runtime: 93 minutes
Recorded Date: April 09, 2020
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  • Changes to the Intake Process, Due Diligence, and Interactions with IRS
  • Relief with Respect to Enforced Collection Activity
  • Relief with Respect to Collection Alternatives
  • Administrative CDP and Collection Review Proceedings before the Tax Court
Runtime: 1 hour, 33 minutes
Recorded: April 9, 2020


The IRS's People First Initiative offers expansive tax collection-related relief for taxpayers affected by COVID-19. This relief, coupled with the unique medical and financial issues presented by COVID-19, requires the IRS and practitioners to revisit their respective strategies concerning tax collection and bankruptcy. The panelists will discuss the relief granted by the People First Initiative and the effect of COVID-19.

This program was recorded on April 9th, 2020.

Provided By

American Bar Association
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Christine Speidel

Assistant Professor of Law
Villanova University Charles Widger School of Law

Christine Speidel directs the Federal Tax Clinic. In the Clinic, she teaches students to practice law by representing needy members of Villanova’s neighboring communities in federal tax disputes. Professor Speidel frequently speaks and writes on issues affecting low-income taxpayers, particularly related to health care reform. Her research interests lie in the intersection of poverty law with tax law and tax procedure. Professor Speidel is a contributor to the Procedurally Taxing blog and an editor of the practice manual Effectively Representing Your Client Before the IRS. Speidel is active in the American Bar Association Section of Taxation, and she is the immediate past chair of the Section’s Pro Bono and Tax Clinics Committee.

Prior to her appointment at Villanova, Professor Speidel practiced law at Vermont Legal Aid. She directed the Vermont Low-Income Taxpayer Clinic and was a staff attorney for Vermont Legal Aid's Office of the Health Care Advocate as well as the Poverty Law Project. She represented low-income individuals in tax, health care, domestic violence, and public benefits matters, and also advocated for systemic policy changes.

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Lawrence A. Sannicandro

McCarter & English

Larry Sannicandro has resolved hundreds of federal and state tax controversies, many of which involved sophisticated and complex tax issues that established legal precedent.

Lawrence (“Larry”) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, and litigation in federal and state courts. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, reporting foreign assets and income, making voluntary disclosures, and representing individuals in criminal tax investigations and prosecutions. Drawing on his unique experience as a former estate and gift tax attorney for the IRS, Larry is particularly well-versed in estate and gift tax planning techniques, as well as the valuation of closely held businesses. He also counsels clients on all facets of business and tax planning, including the formation, operation, transfer, and termination of business entities.

Larry serves the American Bar Association Section of Taxation as the Chair of the Tax Collection, Bankruptcy, and Workouts Committee. On behalf of the American Bar Association Section of Taxation, he has drafted comments to Congress and the IRS on a wide range of tax issues, such as reforming the procedures for auditing and litigating against partnerships and the need to adopt a voluntary disclosure program for unreported cryptocurrency transactions. For his service to the American Bar Association, Larry was awarded the John S. Nolan Fellowship. Larry also teaches a course in tax practice and procedure as an adjunct professor at Fairleigh Dickinson University, and he has taught classes on corporate tax, partnership tax, and negotiations as an adjunct professor at Pace University and a lecturer at Georgetown University Law Center and Rutgers Law School.

Larry is a dedicated pro bono advocate. He works with the After Innocence organization to provide tax-related advice to wrongfully convicted individuals, and he regularly appears on behalf of taxpayers as part of the New York County Lawyers’ Association’s U.S. Tax Court Calendar Call Program. The New York County Lawyers’ Association awarded Larry its Pro Bono Award.

Prior to entering private practice, Larry served as a law clerk for the United States Tax Court, and before that, as an attorney for the IRS. He earned his LL.M. in Taxation from Georgetown University Law Center, J.D. from the University of Florida Levin College of Law, and M.B.A. in Finance from Binghamton University. Larry is a frequent author on tax practice and procedure, having published articles in the Journal of Tax Practice and Procedure, Tax Notes®, TAXES – The Tax Magazine®, and The New Jersey Law Journal. He is the co-author of Qualified Appraiser, Qualified Appraisal: Practice, Procedure, Legal Analysis, and Theory (John Wiley & Sons, Inc. 2017), and Tax Practitioner’s Guide to Identity Theft (CCH, Inc. 1st ed. 2015; 2d ed. 2016). He is also a contributing author to Effectively Representing Your Client Before the IRS (Chapter 10).

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Nancy Ryan

Director, Low Income Tax Clinic
Legal Services of Northern Virginia

Nancy Ryan is the Director of the Low Income Tax Clinic at the Office of Legal Services of Northern Virginia.

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Bridget T. Roberts

Deputy National Taxpayer Advocate
Taxpayer Advocate Service

Bridget T. Roberts is the Deputy National Taxpayer Advocate at the Taxpayer Advocate Service.

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Keith Fogg

Clinical Professor of Law
Harvard Law School

Professor Fogg directs the Federal Tax Clinic at the Legal Services Center where he serves as a clinical professor of law. He joined the Harvard faculty in 2017 after teaching at Villanova Law School for a decade. He got the tax clinic at Harvard off the ground in 2015 and 2016 while serving as a visiting professor. Prior to teaching at Villanova he worked for over 30 years with the Office of Chief Counsel, IRS.

Professor Fogg received his B.A. from the College of William and Mary, his J.D. from the University of Richmond T.C. Williams School of Law and his M.L.T. in tax from the College of William and Mary Marshall Wythe School of Law.

He developed a course for the Georgetown LLM program, Federal Taxation of Bankruptcy and Workouts, which he taught there for 15 years as an adjunct. He has also taught as an adjunct professor at William and Mary and University of Richmond law schools and as a visiting professor at University of Arizona. He is a national authority on tax procedure especially in the area of collection and bankruptcy law as it relates to tax. He co-authors a blog with Professor Les Book,, which focuses on current tax procedure issues. Fogg served as the editor of the ABA Tax Section publication “Effectively Representing Your Client before the IRS” for the 5th, 6th and 7th Editions. He authors the collection chapters in “IRS Practice and Procedure” created by Michael Saltzman and currently edited by Les Book.

He was chosen as the IRS Chief Counsel Robert H. Jackson National Attorney of the Year in 2007 and the ABA Tax Section Janet R. Spragens Pro Bono Award winner in 2015. He is a past chair of the ABA Tax Section Pro Bono and Tax Clinics Committee a past council member of the Section and will begin a term as Vice-Chair for publications in August 2018.

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