Hot IRS Audit Issues: More Money (For Them), More Problems (For Your Clients)?

Jeff Luechtefeld focuses his practice on resolving complex tax controversies with the Internal Revenue Service, both in administrative proceedings and litigation. He represents clients before the United States Tax Court, U.S. district courts, and federal courts of appeals, and develops strategic approaches grounded in a deep understanding of IRS processes and enforcement priorities.

Sean Gannon is a partner in the Atlanta office of the multistate law firm of Bradley Arant Boult Cummings LLP. He is an experienced tax controversy and litigation attorney with a strong technical background and a detailed understanding of IRS procedural matters. His practice focuses on representing clients in IRS examinations, appeals and litigation. Prior to joining Bradley, Sean served as a member of the management group of the tax controversy practice for a Big Four accounting firm, where he assisted clients with their IRS and state tax controversies.

Bruce Ely is a partner in the Birmingham, Alabama office of the multistate law firm of Bradley Arant Boult Cummings LLP and founder of its SALT Practice Group.  He represents taxpayers before various state and local government taxing authorities as well as the tax tribunals and circuit and appellate courts of Alabama and Mississippi, and before the Internal Revenue Service and U.S. Tax Court.

Mr. Ely is Past Co-Chair of the New York University (NYU) Institute on State and Local Taxation, a long-time Fellow of the American College of Tax Counsel, and has been listed in “Best Lawyers in America” and “Super Lawyers” for a number of years.   Until recently, he also served as Co-Chair of the ABA Tax Section SALT Committee’s “Task Force on the State Implications of the New Federal Partnership Audit Rules” and co-authored a model conformity/RAR statute now being advocated to the states.  He is also co-editor of the Bloomberg Tax “Pass-Through Entities Navigator” and serves as Alabama correspondent for both Tax Notes-State and Daily Tax Report.  He is a longtime member of the State Tax Advisory Board for Bloomberg Tax and received Bloomberg’s “State Tax Author of the Year” Award in 2017 and its Franklin C. Latcham Distinguished Service Award in 2021.