Bloomberg Tax Insights & Commentary is featuring a recurring questionnaire of prominent tax professionals who are willing to share their thoughts about their work and the practice of tax these days. This edition features Alissa Gipson, a tax controversy attorney at Chamberlain Hrdlicka in Houston.
What is the biggest challenge that tax practitioners are facing in 2026?
One of the biggest is last year’s reduction in the IRS workforce. Many of the IRS’s most experienced and knowledgeable employees are no longer there and left the agency much sooner than they expected. Those who left didn’t have the opportunity to train their successors under the standard practices for an employee planning to retire. As a result of the abrupt reduction of the IRS workforce, the IRS is even more understaffed than it previously was, so practitioners are experiencing a significant increase in delays and inconsistencies with matters.
For example, I sent a response to the IRS in March alerting them of our efforts toward a client matter. I finally received a response in August, notifying me that the office that received the letter will forward it on to another IRS office. The content of the letter will likely be obsolete by the time it is actually reviewed.
As tax professionals, we are managing clients’ expectations about timelines and the accompanying stresses of years-long controversies with the IRS. We also are working with the IRS’s new procedures to accelerate engagement with certain types of matters to achieve timing efficiencies for better results.
What tax issue keeps you up at night?
The interest and penalty abatement/refund claims that were recently submitted under Section 7508A and the Kwong ruling.
Section 7508A provides the Secretary of the Treasury authority to disregard up to one year when calculating certain items, including interest and penalties, for taxpayers affected by federally declared disasters, significant fires, and terroristic or military actions. The Covid-19 pandemic was federally declared as a disaster; therefore, Section 7508A may apply in certain instances to disregard the appropriate pandemic time frame when computing interest and/or penalties.
The decision in Kwong held that Section 7508A(d) required the Covid-19 postponement period to begin on the earliest incident date and end 60 days after the latest incident date specified in the disaster declaration and held the period was not limited by the one-year cap found in Section 7508A(a). Accordingly, Section 7508(d) allows for a mandatory pandemic postponement for the period from Jan. 20, 2020, through July 10, 2023.
Kwong supports an argument that the Covid-19 mandatory postponement may apply to interest and penalty calculations because Section 7508A(d) required the disregarding of the Covid-19 period in the same manner as Section 7508A(a) requires the disregarding of a period when calculating interest and penalties, among other tax items. Therefore, under Kwong, several claims for refund/abatement were filed by July 10 this year to request the disregard of the pandemic postponement period when calculating interest and/or penalties.
Kwong remains subject to appellate review, so I am interested to see how the IRS handles this unsettled argument.
What’s the biggest lesson you learned in your early years of practice?
The importance of getting involved with your firm or organization outside of your practice. Joining a committee or group allows you to have a stake in and understanding of your workplace, develop meaningful relationships, and feel a deeper sense of community and belonging.
In my first or second year, I joined the Attorney Development Committee. Several firms had publicized recent increases to their maternity leave policy, so I reviewed ours and recognized that the recent increases put our firm behind others. I charted various policies in the Houston area and brought my research to our committee meeting. The committee recognized the need, and the board ultimately approved several improvements. As a new associate, this experience solidified my understanding of our firm’s culture as truly valuing every part of the organization and absolutely impacted my job satisfaction.
What’s the most memorable case you’ve worked on?
A criminal tax fraud case that concluded a few years ago. The government initially believed the small business taxpayer had unreported cash receipts, resulting in over $800,000 due to the IRS. After several years of work with forensic accountants to review and illustrate the business’s finances in light of unexpected circumstances we uncovered, we were able to show the government that the taxpayer was technically due a refund from the IRS!
What was the last thing you believed beyond a reasonable doubt?
No two tax controversy matters are the same. As similar as facts may be, there can never be a copy-and-paste approach to a tax controversy issue, especially once you consider new law, new case law, new guidance, new procedures, etc. The unique facts of each matter are important and often play a large role in the representation and advocacy.
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Reproduced with permission. Published Aug. 21, 2026. Copyright 2026 Bloomberg Industry Group 800-372-1033. For further use please visit https://www.bloombergindustry.com/copyright-and-usage-guidelines-copyright/