George Hani and Caroline Reaves will speak at the American Petroleum Institute (API) 89th Annual Federal Tax Forum on April 23, 2024. In their session, "Litigation and Tax Controversy Update," Hani and Reaves will survey notable tax audit and controversy developments, including the successor to Rev. Proc. 94-69 disclosures, an uptick in challenges under the codified economic substance doctrine, heightened scrutiny of research and experimentation (R&E) credit claims, and a wave of litigation challenges to the validity of regulations.