This week’s ABA Tax Section 2025 May Tax Meeting (program) kicks off today. A highlight is the Teaching Taxation program on Friday on The Future of High-End Tax Enforcement:

A constant source of concern in the U.S. tax system is the ability of wealthy and high-income individuals to avoid paying their “fair share” of taxes. High-end taxpayers often avoid their tax obligations through legal tax avoidance, using statutory and regulatory provisions as Congress and Treasury intended, but they also participate in abusive tax strategies and, in extreme cases, fraud. One recent study has estimated that the tax noncompliance of the top 1% of taxpayers alone results in approximately $175 billion of lost tax revenue each year, or nearly $2 trillion over a decade. At the same time, from 2011 to 2018, the IRS audit rate of millionaires dropped by approximately 80%. Current reductions to tax enforcement resources further exacerbate the potential for high-end taxpayers to outmaneuver the IRS. In response to these developments, this panel will feature three different and new perspectives on how Congress, the Treasury, and the IRS can address the challenge of tax avoidance and noncompliance by high-end taxpayers.

• Joshua Blank (UC-Irvine; Google Scholar) (moderator)
• Ari Glogower (Northwestern; Google Scholar)
• Goldburn Maynard Jr. (Indiana-Kelley, leaving for Connecticut; Google Scholar)
• Emily Satterthwaite (Georgetown; Google Scholar)

Other Tax Profs with speaking roles include: 

• Advanced IRS Collection Topics: Christine Speidel (Villanova; Google Scholar)
• AI-Ing Your Tax Practice – From Audits to Litigation: Sharyn Fisk (Cal Poly; Google Scholar)
• Change is “Gonna” Come: Samantha Galvin (Loyola-Chicago) 
• The Lifecycle of an Attorney: Beverly Winstead (Maryland)
• Protecting and Advancing Rights Through Tax: How Tax Can Move the Needle: Nick Opinsky (Georgetown) (moderator), Tessa Davis (South Carolina), Ellis Duncan (Georgetown), Anthony Infanti (Pittsburgh; Google Scholar)
• Reclaiming U.S. Tax Sovereignty: Michael Graetz (Columbia; Google Scholar)
• Sale, Exchange, and Basis Consequences of Dividing Properties: Roberta Mann (Oregon)
• Tariff(y)ing Tax Exempts: Itai Grinberg (Georgetown)
• Taxpayer Privacy: Issues for Policy and Administration: Caroline Bruckner (American; Google Scholar)
• Zuch v Commissioner: Supreme Court To Tackle Offsets and Mootness Issues: Leslie Book (Villanova; Google Scholar) (moderator), Audrey Patten (Harvard), Caleb Smith (Minnesota) 

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