Faculty Profile: William Pope Jr.

 

PRACTICE AREAS:  

Tax Litigation and Controversy, Criminal Tax Investigations, and Tax Collection (Internal Revenue Service and Tennessee Department of Revenue); 

 

Taxation in Bankruptcies, Insolvencies, and Workouts; Business Workouts, Bankruptcy and Related Litigation.

 

 

From 1974 to 1980, Bob Pope was a trial attorney in the Office of Chief Counsel, Internal Revenue Service.      

 

Mr. Pope focuses on tax procedures and processes of both the Internal Revenue Service and the Tennessee Department of Revenue, with an emphasis on litigation.  He works closely with certified public accountants, tax lawyers, and enrolled agents to define procedures and processes not routinely used by those professionals. Mr. Pope defines realistic legal and practical solutions, including the choices and timing of workouts and bankruptcy, for businesses facing financial problems.

 

Mr. Pope is listed in The Best Lawyers in America (Taxation and Bankruptcy and Creditor/Debtor Rights Law).  He is a Fellow in the American College of Tax Counsel. (www. actconline.org.)

PROFESSIONAL AFFILIATIONS: 

 

- Planning Committee  2007 to Present: "Tennessee Federal Tax Conference" an annual three-day conference held in November sponsored by the Tennessee Scoiety of Ceritfied Public Accountants and the Tennessee Federal Tax  Institute.

- Trustee of The Tennessee Federal Tax Institute. President 2005 and 2006. 

- Served as a director of the Mid-South Commercial Law Institute, and as its treasurer.  

- Southeast Region Bar IRS Liaison Committee since 2002.

- Fellow of the American College of Tax Counsel.

 

 

SECTION ON TAXATION

American Bar Association

 

Mr. Pope was a founding member and the Chair of the Bankruptcy and Workouts Committee of the American Bar Association's Section on Taxation.

 

Bankruptcy Task Force:

1997-2000 Member

2001-2003 Chair

- Worked with Paul Asofsky, meetings with congressional staff members on tax provisions of proposed bankruptcy legislation and drafting of some tax provisions and review of all tax provisions of 2005 Bankruptcy Act (May, 1997 - Bankruptcy Task Force Report).

- Presentation of suggested tax changes to Tax Subcommittee of Bankruptcy Review Commission.

- Monitor congressional consideration of bankruptcy legislation and respond to congressional inquiries on tax provisions.

 

Major Accomplishment:  

When passage of the new bankruptcy legislation was complete, the Bankruptcy Task Force came to its end.  Working with Council members, notably Karen Hawkins, the Task Force was "converted" to a Standing Committee.

 

Bankruptcy and Workouts Committee:

2003-2005 Chair

2006-2010 Regular Participant - Panelist/Speaker

2011-2014 Vice Chair

June 2015 Chair Elect

 

- On passage of the bankruptcy legislation, the Committee made several presentations to assure widespread delivery of the tax changes. 

 

- Committee members address bankruptcy/tax issues at the request of the Section of Taxation, and various committees. 

 

Member, COGS:  2009 - To Date   

 

 

PUBLICATIONS

 

"S" Corporation Federal Tax Status - Property of the Bankruptcy Estate?, Norton's Bankruptcy Law Adviser (July, 2013)

 

Collection Due Process Hearings - The Internal Revenue Manual:  A Statement of Administrative Procedures?, CCH Journal of Tax Practice & Procedure (April-May, 2012) 

 

Federal Income Taxation of the Individual Chapter 11 Debtor and the Bankruptcy Estate: Double Taxation -- Really?, Norton's Bankruptcy Law Adviser (April, 2011, Co-Author:  Frances Sheehy)

 

The Subprime Mortgage Debacle:  A Tax Issue?, Norton's Bankruptcy Adviser (March, 2009)

 

The Internal Revenue Service and Tax Opinions on Litigation Hazards:  Not Work Product!, Tennessee Bar Journal (March, 2008)

 

The Hunt for Tax Accrual Workpapers, Tennessee CPA Journal (November, 2007)

 

Bankruptcy Tax Issues:  The Conflict of Codes!, Enrolled Agents Journal (May-June, 2002)

 

 

LECTURES/PANELS:  

 

Association of Insolvency and Restructuring Advisers

Chattanooga Tax Practitioners' Club

Kentucky Federal Tax Institute

IRS National Tax Forums

Maryland Association of Certified Public Accountants

NYU Institute on Federal Taxation 

Section on Taxation, American Bar Association

Southern Federal Tax Institute

Tennessee Federal Tax Institute

Tennessee Federal Tax Conference

Tennessee Society of Certified Public Accountants

Tennessee Society of Enrolled Agents

Wisconsin Bar Association

 

SEMINAR PRESENTATIONS

 

2015

 

ABA Section on Taxation, Criminal and Civil Penalties Committee, Houston, TX, January 29, 2015

- Bankruptcy:  The Judicial Answer To Unpaid Federal Tax Liabilities

- Discharge of Taxes in the Aftermath of McCoy

 

ABA Business Law Section, Webinar, May 19, 2015

- Discharge of Tax Liabilities In Bankruptcy:  Late Filed Returns and The Internal Revenue Service

 

 

2014

 

ABA Section on Taxation, Bankruptcy and Workout Committee, Phoenix, Arizona, January 23, 2014

- Dealing With State Tax Authorities In Bankruptcy:  Unpaid Federal Tax Liabilities

- THE OFFICE OF PROFESSIONAL RESPONSIBILITY THE IRS COLLECTION PROCESS AND THE BANKRUPTCY WORLD

 

Florida Bar Association, Tax Section, Orlando, Florida, April 24, 2014

- IRS APPEALS -- Appeals Judicial Approach and Culture

- IRS Compliance and Appeals Issues

 

ABA Section of Taxation, Bankruptcy and Workout Committee, Washington, DC, May 8, 2014

- IRS Compliance and Appeals Issues -- The Collection Perspective

- Tax Priorities and Dischargeability:   Application of Sections 507 and 503 of the Bankruptcy Code

 

American Law Institute, Washington, DC, October 15, 2014

- Bankruptcy:  The Judicial Answer To Unpaid Federal Tax Liabilities

 

Tennessee Federal Tax Conference, Brentwood, TN, November 19, 2014

- Circular 230 and the Office of Professional Responsibility (OPR):  Enforcement

- OPR:  Director's Update

 

 

Great Plains Federal Tax Institute (Nebraska CPAs), Omaha, Nebraska, December 4, 2014

- A Tax Map For The Bankruptcy Process - Tax Issues Only

- Using Bankruptcy To Provide Relief From Tax Debt 

 

ABA Criminal Tax Controversy Institute, Las Vegas, NV, December 10, 2014

- Closing the Audit:  The Options.

 

 

2013

 

ABA Tax Section Mid-Year Meeting, Orlando, FL, January 25, 2013

- The Exit Strategy from Retirement Accounts for the Financially Challenged:  The IRS Collection Process and Bankruptcy Protection

- IRS Collection & Bankruptcy Alternatives

- Tough Issues in Bankruptcy Tax and Annual Updates

 

ABA 2013 May Meeting, Washington, DC, May 10, 2013

A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice

 

TN Society of Certified Public Accountants, Chattanooga Tax Practitioners, Chattanooga, TN, July 12, 2013

The IRS Collection Process:  The Taxpayer Advocate, and IRS 2012 "Fresh Start"

 

IRS Nationwide Tax Forum

- Atlanta, GA

August 20-22, 2013

- San Diego, CA

September 16-19, 2013

Tax Debt Relief in Bankruptcy

 

TSCPA - Tennessee Federal Tax Conference, Brentwood, TN, November 20-22, 2013

Two Presentations

- The Internal Revenue Service Examination - How to Handle:  Planning and Pitfalls

- The Internal Revenue Service's Collection Due Process "Hearing":  A Misnomer?  Litigating the Collection Process

 

30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV, December 11-13, 2013

Dialing for Dollars:  The IRS Collection Process - Administrative and Judicial Solutions 

 

 

2012

 

ABA Section on Taxation, Bankruptcy and Workouts Committee 2012 Mid-Year Meeting, February 17, 2012 (Moderator and Prepared Materials)

Tax Litigation:  Tax Court or Bankruptcy Court - When, Where, How and Why

 

ABA Section on Taxation and Bankruptcy and Workouts Committee, May 10-12, 2012 (Moderator and Prepared Materials)

- Top Ten Hot Button Issues - Bankruptcy Tax Procedural Issues* (*and Foot Faults) (A Panel Discussion)

- Bankruptcy, Collections and the Collection Due Process Appeal

 

ABA Section on Taxation and Section of Real Property, Trust and Estate Law - 2012 Joint Fall CLE Meeting, Boston, MA, September 14, 2012

When and How to Withdraw from Representation Consistent with the Ethics Rule

 

National Association of Consumer Bankruptcy Attorneys (NACBA), Amelia Island, FL, November 4-5, 2012

Top Ten "Hot Button" Issues* (*and Foot Faults) - Bankruptcy Tax Procedure (and a bit of Substance) (A Panel Discussion)

 

TSCPA - Tennessee Federal Tax Conference, Franklin, TN, November 14, 2012

Voluntary Disclosure:  Definitions and Mechanics and the 2012 Offshore Voluntary Disclosure

 

ABA 29th Annual National Institute on Criminal Tax Fraud and 2nd National Institute on Tax Controversy, Los Vegas, NV, December 6-7, 2012

Administrative Tax Strategies and Techniques in a Recessionary Economy

 

 

2011

 

ABA 2011 Midyear Meeting of Closely Held Businesses and Bankruptcy & Workouts, Boca Raton, FL, January 21, 2011

Treatment of the Secured Tax Claim in Bankruptcy

 

Chattanooga Tax Practitioners, Chattanooga, TN, April 20, 2011

The IRS Collection Process and the Bankruptcy Alternative

 

American Institute of CPAs (AICPA), Las Vegas, NV, May 5-6, 2011

Unpaid Federal Tax Liabilities, The IRS Collection Process and the Bankruptcy Alternative

 

TSCPA - Tennessee Federal Tax Conference, Brentwood, TN, November 16-18, 2011

Internal Revenue Service Criminal Tax Investigations:  A Primer for "Civil" Tax Advisors

 

 

2010

 

ABA 2010 Midyear Meeting of Closely Held Businesses and Bankruptcy & Workouts, San Antonio, TX, January 22, 2010

Tax and Bankruptcy Considerations When Representing Financially Distressed Entities and Their Owners

 

ABA Tax Section - State Bar of Wisconsin, Milwaukee, WI, March 12, 2010

Let's Make A Deal With The IRS - OR - Is A Bankruptcy Discharge the Answer - Tax Implications:  Workouts and Bankruptcy

 

TN Society of Enrolled Agents - TSEA Annual Tax Seminar, Brentwood, TN, May 20-21, 2010

Tax Issues in Bankruptcy

 

9th Annual NC/SC Tax Section, Kiawah Island, SC, May 28-30, 2010

Tax Issues in Bankruptcy

 

Maryland Association of Certified Public Accountants - Advanced Tax Institute, Baltimore, MD, November 2, 2010

Unpaid Federal Tax Liabilities

 

TN Society of Certified Public Accountants (TSCPA), 2010 Tennessee Federal Tax Conference, Franklin, TN, November 18, 2010

Three Presentations: 

- Bankruptcy Taxation:  The Tax Life Cycle of a Business Bankruptcy

- IRS Tax Penalties:  "The Practical Approach" (A Panel Discussion)

- Voluntary Disclosure:  Correcting Errors and Eliminating Criminal Prosecution

 

 

2009

 

2009 IRS Nationwide Tax Forum

Federal Tax Treatment of Debt Workouts

 

Southern Federal Tax Institute, Atlanta, GA, October 19-23, 2009

IRS Collection Issues And The Bankruptcy Alternatives

 

ABA CLE Teleconference, October, 28, 2009

Let's Make a Deal With the IRS - OR - Is Discharge the Answer?

 

Georgia Tax Forum, Savannah, GA, November 11-14, 2009

The IRS v. The Bankruptcy Code

 

Tennessee Federal Tax Conference, Brentwood, TN, November 11-18, 2009

IRS Collection Issues:  Bankruptcy vs. IRS Administrative Options