The Tax Court’s New Limited Appearance Procedure: Procedural, Ethical, and Practical Considerations

Level: Advanced
Runtime: 90 minutes
Recorded Date: October 21, 2019
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  • The Prodedure - Overview
  • Background on the New Procedure and the Need
  • Discussion of the New Procedure
  • A Practical Process
  • Ethical Considerations
  • The Future of the Procedure
  • Q & A
Runtime: 1 hour 30 minutes
Recorded: October 21, 2019


The U.S. Tax Court's Limited Entry of Appearance Procedure allows practitioners admitted to practice and in good standing with the Court to file a Limited Entry of Appearance during scheduled trial sessions. The practitioner, upon concurrence by petitioner(s), may limit an appearance to a date or dates during a scheduled session by filing a form developed by the Court.

This panel will discuss the background and development of the procedure, provide an overview of the procedure, including the form and the steps necessary for a practitioner to take to enter a limited appearance, and discuss practical and ethical considerations when using the procedure.

This program was recorded on October 21st, 2019.

Provided By

American Bar Association


Caleb Smith

Associate Clinical Professor, Ronald L. Mankoff Clinic
University of Minnesota Law School

Professor Caleb Smith joined the faculty in 2017 as visiting associate professor of clinical law. Before joining the Ronald M. Mankoff Tax Clinic, Smith most recently worked as a clinical fellow at Harvard Law School’s Federal Tax Clinic. He has given several presentations at national ABA Tax Section conferences on low-income tax issues, and he co-authored a chapter on the Earned Income Tax Credit in the forthcoming seventh edition of the ABA’s Effectively Representing Your Client Before the IRS.

Since 2008 Smith has worked with low-income taxpayer issues: prior to law school as program manager at Minnesota’s largest tax assistance nonprofit; during law school as student director of his school’s Federal Tax Clinic; and after law school as an attorney at low-income taxpayer clinics in Minneapolis and Boston. In addition to directing the Federal Tax Clinic, Smith teaches Federal

Jennifer Breen

Morgan Lewis & Bockius

Jennifer Breen concentrates her practice on tax controversy and planning matters, with an emphasis on audits and controversies and Internal Revenue Service (IRS) administrative proceedings. Jennifer routinely handles matters involving US federal income tax, foreign tax, state and local corporate and business tax, and sales and use tax. She has experience representing major corporations, partnerships, S corporations, and individuals in resolving domestic and international compliance and controversy issues before the IRS.

Prior to joining Morgan Lewis, Jennifer served as director of tax controversy at Mattel, Inc., where she developed and executed audit strategies, responded to information requests from respective tax authorities, and negotiated and resolved controversy matters. She was also responsible for accounting for income taxes under ASC 740, managing the company’s global reportable transaction compliance, and ensuring compliance under the Foreign Account Tax Compliance Act.

Jennifer also served as director of tax controversy and regulatory services at PricewaterhouseCoopers LLP for more than seven years. She began her legal career as a lawyer with the IRS Office of Chief Counsel in Washington, DC, where she represented the IRS before the US Tax Court and advised on issues relating to practice and procedure.

Jennifer received her JD from the University of Houston Law Center in 2001.

Pamela W. Fuller

Senior Technician Reviewer
Office of Chief Counsel IRS

Pamela Wilson Fuller is a Senior Technician Reviewer at the Office of Chief Counsel at the IRS.

Hon. Lewis R. Carluzzo

Chief Special Trial Judge
U.S. Tax Court

Lewis R. Carluzzo is an Article I special trial judge for the United States Tax Court. He was appointed to the court on August 7, 1994.

Carluzzo began his legal career as a law clerk to a New Jersey Superior Court judge. Next, he became an associate with a private firm, as well as a city prosecutor for Bridgeton. From 1977 to 1994, Carluzzo was an attorney with the Internal Revenue Service in the Office of the Chief Counsel. He also served as Special Trial Attorney of the Association Chief Counsel.

Carluzzo received his undergraduate and J.D. degrees from Villanova University in 1971 and 1974, respectively.

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