BBA Audits: What Tax Attorneys Need to Know

Jennifer Black is a managing director in Citrin Cooperman’s National Tax Office and has over two decades of combined legal and accounting experience. Jenni has extensive experience dealing with complex tax issues, including partnership audit procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA), the interaction between TEFRA and collection due process (CDP) procedures, and disclosure issues involving section 6103, the Privacy Act, and the Freedom of Information Act (FOIA).

Prior to Citrin Cooperman, Jenni was senior counsel for the Internal Revenue Service’s (IRS) Office of Chief Counsel in the Procedure and Administration Division. Jenni served as the primary resource for both BBA and TEFRA matters and was essential in implementing the BBA regime, including developing policy, interpreting statutes, authoring regulations, reviewing and creating new forms, and assisting in developing internal procedures to perform examinations under the BBA.

In her time at the IRS, Jenni was the recipient of many national awards, including four Commissioner Awards, a Chief Counsel award, two Large Business and International (LB&I) division awards, two national team awards, and an individual merit award from the Office of Fraud Enforcement.

Robert Horwitz is an attorney at Hochman Salkin Toscher Perez P.C. has over 35 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 years.  He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.