Christopher Rizek Speaks to Law360 on IRS Enforcement

As the IRS ramps up its enforcement on syndicated conservation easements, cryptocurrency transactions and microcaptive insurance arrangements, the efforts will be guided by a veteran Eversheds Sutherland litigator who once squared off against the agency over tax shelter transactions.

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In the panel discussion with Cullinan in Las Vegas, Christopher Rizek, a Member at Caplin & Drysdale, offered a counterargument against simply mirroring the stance of the IRS and pouring cold water on certain targeted investments like syndicated conservation easements.

“Well, you know, some clients take offense to being terrorized into quitting their business,” Rizek told Cullinan during the panel.

Nevertheless, Rizek and Larry Campagna, shareholder at Chamberlain Hrdlicka White Williams & Aughtry PC, said Cullinan's public remarks affect how tax litigators advise clients on prospective investments.

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