"The first thing we do, let's kill all the lawyers"

Justice John Paul Stevens understood why Shakespeare put those oft-misquoted words into the mouth of the villainous Dick the Butcher. As Justice Stevens explained: "Shakespeare insightfully realized that disposing of lawyers is a step in the direction of a totalitarian form of government."

This timely panel will discuss the constitutionality of the Trump administration's series of unprecedented attacks on prominent law firms and sitting judges, the reaction from the courts, and how members of the legal profession can defend the Rule of Law.

Participants will be introduced to approaches to mediation, managing difficult clients, effectively communicating a client’s position to the mediator, positioning a client for resolution, and time management during mediation. Hypotheticals will be presented to illustrate different strategies and techniques.

The session will provide an in-depth look at how the Bipartisan Budget Act (BBA) has transformed partnership audits, including the centralized partnership audit procedures under IRC §§ 6221–6241. Jennifer Black (Citrin Cooperman) and Robert Horwitz (Hochman Salkin Toscher Perez, P.C.) will guide attendees through the key components of a BBA audit—from the designation and powers of the Partnership Representative, to the calculation and modification of imputed underpayments, to the decision-making process between paying at the partnership level versus electing a push-out.

The program will also cover the mechanics and strategy behind Administrative Adjustment Requests (AARs), the strict timing rules and procedural traps, and how tiered partnership structures complicate compliance and reporting. Whether you advise on partnership formation, prepare partnership returns, or represent clients before the IRS, this presentation will deliver essential tools for navigating the BBA regime in practice.