AAA-CPA 2026 Annual Meeting
Conference Agenda (subject to change)
Tuesday, June 23, 2026
Location: Holiday Inn Missoula Downtown
Arrival and Optional Morning Activities
4:00 pm - 6:00 pm
Academy of Attorney CPAs Board Meeting & Annual Membership Meeting
Open to all, only Directors can vote
7:00 pm – 10:00 pm
Welcome Reception & Dinner | Networking
Buffet Dinner and hosted bar with 2 drink tickets; cash bar follows
Wednesday, June 24, 2026
Location: University of Montana Alexander Blewett III School of Law
8:00 am - 8:45 am
Breakfast
9:00 am - 10:30 am
Spouse & Guest Breakfast (Holiday Inn Missoula Downtown)
8:30 am – 9:00 am
Current Happenings at the IRS
Mark Friedlich, Esq., CPA, Vice President, Government Affairs, Wolters Kluwer
Moderator: David De Jong, LLM, CPA, Stein Sperling, Principal
Over the past 18 months, the IRS has undergone unprecedented transformation, including significantly reduced staff and budgets while accelerating its investment in artificial intelligence and machine learning to drive compliance and enforcement. These rapid shifts are reshaping how tax professionals must engage with the agency and serve their clients effectively in this new environment.
Join Mark Friedlich, one of the most respected voices in the tax community, for an in-depth discussion on the IRS's evolving priorities and practices. Mark's distinguished career includes leadership roles as COO and Managing Principal at PwC, Vice President of Tax, Accounting, and Audit at Thomson Reuters and Wolters Kluwer, and now Of Counsel to Hall Lundstedt, where he specializes in tax controversy.
A prolific author, Adjunct Tax Professor, and sought-after speaker, Mark has spent decades shaping thought leadership at the intersection of tax policy, practice, and technology. Beyond his credentials, Mark brings a unique and trusted perspective, built on decades-long relationships with numerous former IRS Commissioners and senior officials, as well as close connections within Congress and several administrations.
In a Q&A conversation with David DeJong, Mark will share his firsthand impressions of where the IRS stands today, insights from his direct conversations with current and former leaders, and what he foresees for the future of tax administration, enforcement, and practitioner engagement.
9:00 am – 10:00 am
Taxation of Cryptocurrency and Digital Assets
Joshua Smeltzer, Esq, Partner, Gray Reed
Angela Alloju, Esq., Associate, Gray Reed
A review of the tax considerations and concerns associated with acquiring, holding, and transacting in cryptocurrency and digital assets. The presentation will include practical examples, talk about whether the Wash Sale Rules apply and teach people about “staking” and other digital asset incentives and their associated tax implications. We will address alternatives to direct investments in Crypto.
10:00 am – 10:15 pm
Break
10:15 am – 11:15 am
MT DOR Priorities and Policies: Now and Going Forward
Brendan Beatty, Director, Montana Department of Revenue
11:15 am – 12:15 pm
Emerging Trends in AI at the Intersection of Law & Accounting
Robert Russell O’Haver, Northeastern University
The presentation will focus on how AI and other emerging technologies are impacting on the fields of law, accounting, and wealth management. The focus will be on cases in each field and Mr. O’Haver’s experience in effective ways to learn and apply AI techniques to the work of practitioners in these fields.
12:15 pm – 1:30 pm
Lunch: Honoring the Legacy
Featuring Attorney CPA Foundation Presentation
1:30 pm – 2:45 pm
Education Session TBD
2:45 pm – 3:00 pm
Break – Ice Cream/Frozen Treats
3:00 pm – 4:00 pm
Name Image Likeness
Sarah Green, Senior Managing Associate, Dentons
Thomas F. Smith, Partner, Prager Metis
4:00 pm – 5:10 pm
Private Equity (“PE”) and its Impact on the Accounting Profession Practice and Structure
Rick Reisig, Pinion, LLC & KCoe Isom, LLP; former Chairman, National Association of State Boards of Accountancy (NASBA) and Montana Board of Public Accountants
Former NASBA and Montana State Board of Accountancy Chair, Rick Reisig explores how PE is burgeoning in the CPA profession and how firms are restructuring their practices to balance the need for PE funding with the ethical obligations of the profession. Following Rick’s exploration, Rick and our own Anthony Tucci will have a dialogue regarding how State Boards of Accountancy are reacting to this trend and the concerns that the profession faces in light of PE.
6:30 pm/7:00 pm
Dine Arounds
Sign up via Sign Up Genius or at conference registration desk
9:00 pm - 11:00 pm
No-host hospitality/networking (Holiday Inn Presidential Suite)
Thursday, June 25, 2026
Location: Holiday Inn Missoula Downtown
7:45 am - 9:00 am
Breakfast
8:30 am – 8:35 am
Opening Remarks
E. Martin Davidoff, CPA, Esq., Partner In Charge, National Tax Controversy, Prager Metis CPAs; Founder, Davidoff Tax Law
8:35 am – 9:35 am
How to Deal with Business “Divorces” – A View from a Seasoned Litigator
Michele Friend, JD, CPA, Principal, Offit Kurman
Tips and tricks on negotiating settlements and obstacles to those settlements. How to bring parties together. The particular issues generated from the CA property tax rules in connection with real estate ventures. Issues that can be prevented by nuanced drafting of LLC/Partnership Agreement. Samples of bizarre or simply bad draftsmanship.
9:35 am – 9: 50 am
Break
9:50 am -10:50 am
Deep Fakes, Real Threats: Cybercrime’s AI Evolution
Sherri Davidoff, Founder, LMG Security
Cybercriminals are using AI to attack your bottom line—and undermine your technology. Voice clones of executives. Fake videos demanding payment. AI-generated emails that slip past your filters and fool even seasoned staff. These attacks aren’t theoretical—they’re happening now, and they’re costing organizations millions. Join us for a candid, eye-opening session on the latest AI-powered cyber threats. You'll:
- See real-world examples of deep fake attacks targeting leadership, finance staff, attorneys, and more
- Understand how these threats undermine financial controls and client trust
- Learn actionable strategies to protect yourself and your organization
This session will help you build an informed, AI-aware cyber defense strategy.
10:50 am – 12:05 pm
Audit Reconsideration – The Art of Second Chances
Nicole Bononi-Wilson, Senior Manager - Tax Controversy, Prager Metis CPAs
Robbin Caruso, Co-Partner In Charge-National Tax Controversy, Prager Metis CPAs
In this insightful session, we will explore the complex process of audit reconsideration, during which the IRS reassesses prior audit results concerning unpaid taxes or reversed credits. You will learn when it is appropriate to request an audit reconsideration, and the steps involved in making that request. For instance, scenarios such as clients disputing IRS audit findings or dealing with a Substitute for Return are critical elements we will address. By the end of this session, you will be equipped with both knowledge and practical strategies to navigate this important aspect of tax compliance.
12:05 pm – 1:30 pm
Lunch on Own
12:45 pm – 6:00 pm
Optional Activity: choice of white water rafting or river float (includes box lunch and transportation to/from river; add-on at registration; pricing TBA)
5:00 pm – 9:00 pm (optional, on your own)
Downtown tonight – 25th Season – Caras Park, Missoula
Music, Artists, Food Trucks – Carousel & Playground for children.
Flexible – Stop by anytime during this window to experience a fun Missoula event.
7:00 pm – 9:30 pm;
Dine Arounds (optional, individual responsibility)
Sign up via Sign Up Genius or at conference registration
9:00 pm - 11:00 pm
No-host hospitality/networking
9:00 pm - 11:00 pm
No-host hospitality/networking (Holiday Inn Presidential Suite)
Friday, June 26, 2026
Location: Holiday Inn Missoula Downtown
7:45 am - 9:00 am
Breakfast
8:30 am - 9:30 am
State Domicile/Residency Tax Issues: A Sophisticated Approach
Mark Klein, Partner, Hodgson Russ LLP
9:30 am - 9:45 am
Break
9:45 am - 11:00 am
Best Practices for Securing IRS Refunds
Lisa Nelson, Esq., LLM in Taxation, Partner, Taylor Nelson Amitrano LLP
Melissa Briggs, Esq., Principal, Hochman Salkin Toscher Perez P.C.
Melissa and Lisa will discuss Administrative Claims for refund and focus on timelines to ensure one’s capability to files suit, including the utilization of form 907. They will discuss:
Administrative Section
• The basics of administrative claims for refunds;
• The basic timing rules on when you can bring a lawsuit;
• Detailed review of statutory and regulatory provisions;
• Hypotheticals of calculations: filing date, extension, payment date, movement of payments, deposits (will use redacted example transcripts and forms);
• Any timing limitations if a refund is approved but not paid to the taxpayer;
• How to extend the time for administrative considerations via form 907; and
• Any timing limitations if “Nothing Happens” to a refund claim;
• Current challenges with IRS staffing issues.
Litigation Section
• Choice of Forum: District Court, Court of Federal Claims, Bankruptcy Court;
• The Complaint: Rules, Tips, Samples;
• Discovery: Rules, Scope, Practice Tips;
• Dispositive Motions;
• Settlement : Detailed explanation of process and authority, tips;
• Trial.
11:00 am - 12:05 pm
Taxation of Sexual Abuse Damages
Robert Wood, Esq., Managing Partner, Wood LLP
Optional Afternoon Activities - TBD
5:30 pm – 6:30 pm (Optional – Sign up in Advance, Additional Fee Required; Holiday Inn Presidential Suite)
Optional Whiskey Tasting with Montana’s Premier Expert
Experience a private tasting with Kevin Head, owner of the Rhino and one of the nation’s top whiskey experts. Enjoy a curated selection of local Montana whiskeys and rare, handpicked favorites.
7:00 pm - 10:30 pm
Cocktail Reception & Installation Dinner (Missoula Public Library)
Attire: Business/Cocktail
Saturday, June 27, 2026
Location: Holiday Inn Missoula Downtown
8:00 am - 9:40 am
Education Session
Juices/Coffee/Fruit and Breads available during session.
9:40 am - 12:00 pm
Missoula Farmer’s Market (Optional)
Check out/Travel Home
Tuesday, June 23, 2026
Location: Holiday Inn Missoula Downtown
Arrival and Optional Morning Activities
4:00 pm - 6:00 pm
Academy of Attorney CPAs Board Meeting & Annual Membership Meeting
Open to all, only Directors can vote
7:00 pm – 10:00 pm
Welcome Reception & Dinner | Networking
Buffet Dinner and hosted bar with 2 drink tickets; cash bar follows
Wednesday, June 24, 2026
Location: University of Montana Alexander Blewett III School of Law
8:00 am - 8:45 am
Breakfast
9:00 am - 10:30 am
Spouse & Guest Breakfast (Holiday Inn Missoula Downtown)
8:30 am – 9:00 am
Current Happenings at the IRS
Mark Friedlich, Esq., CPA, Vice President, Government Affairs, Wolters Kluwer
Moderator: David De Jong, LLM, CPA, Stein Sperling, Principal
Over the past 18 months, the IRS has undergone unprecedented transformation, including significantly reduced staff and budgets while accelerating its investment in artificial intelligence and machine learning to drive compliance and enforcement. These rapid shifts are reshaping how tax professionals must engage with the agency and serve their clients effectively in this new environment.
Join Mark Friedlich, one of the most respected voices in the tax community, for an in-depth discussion on the IRS's evolving priorities and practices. Mark's distinguished career includes leadership roles as COO and Managing Principal at PwC, Vice President of Tax, Accounting, and Audit at Thomson Reuters and Wolters Kluwer, and now Of Counsel to Hall Lundstedt, where he specializes in tax controversy.
A prolific author, Adjunct Tax Professor, and sought-after speaker, Mark has spent decades shaping thought leadership at the intersection of tax policy, practice, and technology. Beyond his credentials, Mark brings a unique and trusted perspective, built on decades-long relationships with numerous former IRS Commissioners and senior officials, as well as close connections within Congress and several administrations.
In a Q&A conversation with David DeJong, Mark will share his firsthand impressions of where the IRS stands today, insights from his direct conversations with current and former leaders, and what he foresees for the future of tax administration, enforcement, and practitioner engagement.
9:00 am – 10:00 am
Taxation of Cryptocurrency and Digital Assets
Joshua Smeltzer, Esq, Partner, Gray Reed
Angela Alloju, Esq., Associate, Gray Reed
A review of the tax considerations and concerns associated with acquiring, holding, and transacting in cryptocurrency and digital assets. The presentation will include practical examples, talk about whether the Wash Sale Rules apply and teach people about “staking” and other digital asset incentives and their associated tax implications. We will address alternatives to direct investments in Crypto.
10:00 am – 10:15 pm
Break
10:15 am – 11:15 am
MT DOR Priorities and Policies: Now and Going Forward
Brendan Beatty, Director, Montana Department of Revenue
11:15 am – 12:15 pm
Emerging Trends in AI at the Intersection of Law & Accounting
Robert Russell O’Haver, Northeastern University
The presentation will focus on how AI and other emerging technologies are impacting on the fields of law, accounting, and wealth management. The focus will be on cases in each field and Mr. O’Haver’s experience in effective ways to learn and apply AI techniques to the work of practitioners in these fields.
12:15 pm – 1:30 pm
Lunch: Honoring the Legacy
Featuring Attorney CPA Foundation Presentation
1:30 pm – 2:45 pm
Education Session TBD
2:45 pm – 3:00 pm
Break – Ice Cream/Frozen Treats
3:00 pm – 4:00 pm
Name Image Likeness
Sarah Green, Senior Managing Associate, Dentons
Thomas F. Smith, Partner, Prager Metis
4:00 pm – 5:10 pm
Private Equity (“PE”) and its Impact on the Accounting Profession Practice and Structure
Rick Reisig, Pinion, LLC & KCoe Isom, LLP; former Chairman, National Association of State Boards of Accountancy (NASBA) and Montana Board of Public Accountants
Former NASBA and Montana State Board of Accountancy Chair, Rick Reisig explores how PE is burgeoning in the CPA profession and how firms are restructuring their practices to balance the need for PE funding with the ethical obligations of the profession. Following Rick’s exploration, Rick and our own Anthony Tucci will have a dialogue regarding how State Boards of Accountancy are reacting to this trend and the concerns that the profession faces in light of PE.
6:30 pm/7:00 pm
Dine Arounds
Sign up via Sign Up Genius or at conference registration desk
9:00 pm - 11:00 pm
No-host hospitality/networking (Holiday Inn Presidential Suite)
Thursday, June 25, 2026
Location: Holiday Inn Missoula Downtown
7:45 am - 9:00 am
Breakfast
8:30 am – 8:35 am
Opening Remarks
E. Martin Davidoff, CPA, Esq., Partner In Charge, National Tax Controversy, Prager Metis CPAs; Founder, Davidoff Tax Law
8:35 am – 9:35 am
How to Deal with Business “Divorces” – A View from a Seasoned Litigator
Michele Friend, JD, CPA, Principal, Offit Kurman
Tips and tricks on negotiating settlements and obstacles to those settlements. How to bring parties together. The particular issues generated from the CA property tax rules in connection with real estate ventures. Issues that can be prevented by nuanced drafting of LLC/Partnership Agreement. Samples of bizarre or simply bad draftsmanship.
9:35 am – 9: 50 am
Break
9:50 am -10:50 am
Deep Fakes, Real Threats: Cybercrime’s AI Evolution
Sherri Davidoff, Founder, LMG Security
Cybercriminals are using AI to attack your bottom line—and undermine your technology. Voice clones of executives. Fake videos demanding payment. AI-generated emails that slip past your filters and fool even seasoned staff. These attacks aren’t theoretical—they’re happening now, and they’re costing organizations millions. Join us for a candid, eye-opening session on the latest AI-powered cyber threats. You'll:
- See real-world examples of deep fake attacks targeting leadership, finance staff, attorneys, and more
- Understand how these threats undermine financial controls and client trust
- Learn actionable strategies to protect yourself and your organization
This session will help you build an informed, AI-aware cyber defense strategy.
10:50 am – 12:05 pm
Audit Reconsideration – The Art of Second Chances
Nicole Bononi-Wilson, Senior Manager - Tax Controversy, Prager Metis CPAs
Robbin Caruso, Co-Partner In Charge-National Tax Controversy, Prager Metis CPAs
In this insightful session, we will explore the complex process of audit reconsideration, during which the IRS reassesses prior audit results concerning unpaid taxes or reversed credits. You will learn when it is appropriate to request an audit reconsideration, and the steps involved in making that request. For instance, scenarios such as clients disputing IRS audit findings or dealing with a Substitute for Return are critical elements we will address. By the end of this session, you will be equipped with both knowledge and practical strategies to navigate this important aspect of tax compliance.
12:05 pm – 1:30 pm
Lunch on Own
12:45 pm – 6:00 pm
Optional Activity: choice of white water rafting or river float (includes box lunch and transportation to/from river; add-on at registration; pricing TBA)
5:00 pm – 9:00 pm (optional, on your own)
Downtown tonight – 25th Season – Caras Park, Missoula
Music, Artists, Food Trucks – Carousel & Playground for children.
Flexible – Stop by anytime during this window to experience a fun Missoula event.
7:00 pm – 9:30 pm;
Dine Arounds (optional, individual responsibility)
Sign up via Sign Up Genius or at conference registration
9:00 pm - 11:00 pm
No-host hospitality/networking
9:00 pm - 11:00 pm
No-host hospitality/networking (Holiday Inn Presidential Suite)
Friday, June 26, 2026
Location: Holiday Inn Missoula Downtown
7:45 am - 9:00 am
Breakfast
8:30 am - 9:30 am
State Domicile/Residency Tax Issues: A Sophisticated Approach
Mark Klein, Partner, Hodgson Russ LLP
9:30 am - 9:45 am
Break
9:45 am - 11:00 am
Best Practices for Securing IRS Refunds
Lisa Nelson, Esq., LLM in Taxation, Partner, Taylor Nelson Amitrano LLP
Melissa Briggs, Esq., Principal, Hochman Salkin Toscher Perez P.C.
Melissa and Lisa will discuss Administrative Claims for refund and focus on timelines to ensure one’s capability to files suit, including the utilization of form 907. They will discuss:
Administrative Section
• The basics of administrative claims for refunds;
• The basic timing rules on when you can bring a lawsuit;
• Detailed review of statutory and regulatory provisions;
• Hypotheticals of calculations: filing date, extension, payment date, movement of payments, deposits (will use redacted example transcripts and forms);
• Any timing limitations if a refund is approved but not paid to the taxpayer;
• How to extend the time for administrative considerations via form 907; and
• Any timing limitations if “Nothing Happens” to a refund claim;
• Current challenges with IRS staffing issues.
Litigation Section
• Choice of Forum: District Court, Court of Federal Claims, Bankruptcy Court;
• The Complaint: Rules, Tips, Samples;
• Discovery: Rules, Scope, Practice Tips;
• Dispositive Motions;
• Settlement : Detailed explanation of process and authority, tips;
• Trial.
11:00 am - 12:05 pm
Taxation of Sexual Abuse Damages
Robert Wood, Esq., Managing Partner, Wood LLP
Optional Afternoon Activities - TBD
5:30 pm – 6:30 pm (Optional – Sign up in Advance, Additional Fee Required; Holiday Inn Presidential Suite)
Optional Whiskey Tasting with Montana’s Premier Expert
Experience a private tasting with Kevin Head, owner of the Rhino and one of the nation’s top whiskey experts. Enjoy a curated selection of local Montana whiskeys and rare, handpicked favorites.
7:00 pm - 10:30 pm
Cocktail Reception & Installation Dinner (Missoula Public Library)
Attire: Business/Cocktail
Saturday, June 27, 2026
Location: Holiday Inn Missoula Downtown
8:00 am - 9:40 am
Education Session
Juices/Coffee/Fruit and Breads available during session.
9:40 am - 12:00 pm
Missoula Farmer’s Market (Optional)
Check out/Travel Home
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