Let’s Talk About Tax – An Annual Sampler 2026

Overview

Registration is now open for the 2026 Let’s Talk About Tax – An Annual Sampler Event. On Tuesday, May 19, you’re invited to join Fredrikson’s Tax Disputes & Litigation Group for an afternoon of tax topics (including an engaging Ethics game show session!), a networking lunch, and evening happy hour with live music. You won’t want to miss the excitement of this year’s event, which will include guest appearances by Kyle Brehm of Jones Walker, Jaye Calhoun from Kean Miller, Mike Daman from Target, Marilyn Wethekam, of the Council On State Taxation, and Chris Wohnoutka from UnitedHealth Group.

For more information on how to register, email events@fredlaw.com.

Agenda

Sessions and Objectives

12:00-1:00 p.m.
Ethics Feud: Wizard Says….Check the Ethics Rules
1.0 Ethics CLE & CPE Credit

Session Description: Step into a wicked game of Ethics Feud, where good intentions, popular answers, and emerging technology collide. In this interactive, Family‑Feud‑style game show, tax professionals will compete to identify how lawyers and accountants think ethical questions should be answered — and how the rules actually require them to be answered. Drawing on Wicked‑inspired themes of perception versus reality and the difficulty of labeling conduct as purely “good” or “wicked,” the session will explore core ethical obligations in tax practice, including confidentiality, advocacy, judgment, and the growing role of artificial intelligence in tax compliance and advice. Through fast‑paced hypotheticals, audience participation, and AI‑influenced scenarios, participants will confront whether the most “popular” answers still hold up in an era of automation, generative tools, and evolving professional standards. This session qualifies for one hour of Ethics CLE and CPE credit.

Learning Objectives:
After attending the session, the participant will be able to:

1. Identify the ethical roles and responsibilities of tax advisors, including duties to clients, taxing authorities, and the profession, and how those duties can conflict in real‑world practice.
2. Distinguish between tax avoidance and tax evasion, including how emerging technologies and AI‑assisted tools can blur ethical and legal boundaries.
3. Assess ethical risks and judgment calls through interactive scenarios, recognizing how “popular” answers may differ from professional responsibility rules and ethical requirements.

Host:
Masha Yevzelman, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN

Contestants:
Jaye Calhoun, Esq.
Partner
Kean Miller
New Orleans, LA

Michael Daman
Director – State Tax Controversy
Target Corporation
Minneapolis, MN

Christopher Wohnoutka
Senior Tax Director
UnitedHealth Group
Minnetonka, MN

1:00-1:10 p.m.
Networking Break

1:10-1:40 p.m.
Defying Gravity: Working with Government Without Losing Your Balance

Session Description: Tax audits and property tax appeals are not just matters of tax law — they are a trip down the yellow brick road of strategy, timing, and unlikely alliances. In this fast‑paced session, you will learn spellbinding tactics for navigating federal, state, and local authorities in tax audits and property tax appeals, from the first ominous information request to the final curtain call. Discover how to work effectively with IRS and DOR examiners, read the hidden motives of county assessors and government attorneys, and know precisely when to rise above the fray and escalate issues to higher powers. You will leave ready to defy expectations with smart negotiation strategies and real‑world insights that help manage risk, capture leverage, and bring even the most daunting audits and property tax disputes to a satisfyingly wicked conclusion.

Learning Objectives:

1. Recognize and implement effective strategies for achieving successful audit and appeal outcomes, from responding to initial information requests through final resolution.
2. Evaluate the motivations of IRS and DOR examiners, as well as county assessors and attorneys, to communicate persuasively, establish credibility, and determine when and how to escalate issues to supervisory levels during audits and appeals.
3. Apply practical negotiation and risk‑management techniques to reach favorable resolutions while minimizing disputes and unnecessary controversy.

Speakers:
Teri Jackson, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN

Lynn Linné, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN

1:40-2:25 p.m.
Is the Wizard Always Right? Judicial Deference in State Tax Cases

Session Description: After Loper Bright Enterprises overturned Chevron deference, taxpayers may have a chance to question whether state revenue departments have been playing the Wizard for too long. This session examines how states are responding to the federal retreat from deference and what that shift means for challenging tax assessments grounded in agency overreach. Following the yellow brick road through recent state court decisions and legislative developments, the speakers will highlight new opportunities for taxpayers to argue that revenue departments have exceeded their authority — whether through aggressive interpretations, expansive regulations, or guidance untethered from statute. The session will also explore how Loper Bright and its emerging state‑level progeny may help taxpayers reframe disputes, defy deference, and force courts to look behind the Emerald Curtain when the executive branch claims to speak with unquestioned authority.

Learning Objectives:

After this session, participants will be able to:

1. Analyze how states are interpreting and applying the principles form Loper Bright in tax contexts.
2. Evaluate the extent to which state tax assessments can be challenged based on claims of executive overreach.
3. Identify strategies taxpayers are using to contest state agency interpretations post-Loper Bright.
4. Consider practical approaches for compliance and controversy in light of evolving deference standards.

Speakers:
Jaye Calhoun, Esq.
Partner
Kean Miller
New Orleans, LA

Dylan Saul
Associate
Fredrikson & Byron, P.A.
Minneapolis, MN

2:25-2:35 p.m.
Networking Break

2:35-3:20 p.m.
Popular or Wicked: A Sales & Use Tax Duel

Session Description: In this Wicked debate, Kyle and Masha will take opposing sides on recent sales and use tax trends, squaring off in a fast‑paced, battle‑style format. The session will explore key legislative, administrative, and judicial developments, challenging participants to decide which positions are “good,” which are “evil,” and which fall somewhere in between. Designed to be both engaging and substantive, this program offers practitioners a sharp, practical look at the sales and use tax issues shaping the current landscape.

Learning Objectives:

1. Identify recent legislative, administrative, and judicial developments affecting sales and use tax.
2. Analyze competing state and taxpayer positions on current sales and use tax issues.
3. Apply practical insights from recent trends to sales and use tax planning and controversy matters.

Moderator:
Jennifer Pusch, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN

Speakers:
Masha Yevzelman, Esq.
Shareholder
Fredrikson & Byron
Minneapolis, MN 

Kyle Brehm, Esq.
Partner
Jones Walker
Eden Prairie, MN

3:20-3:30 p.m.
Networking Break

3:30-4:30
COST Update: When Good Policy Turns Wicked: Lessons from State Tax Administration

Session Description: What makes state tax policy effective — and how can taxpayers help shape it? This session explores the essential components of sound state and local tax policy through the lens of the Council On State Taxation’s (COST) national legislative priorities and its objective evaluations of state administrative practices.

Learning Objectives:

After attending this session, participants will be able to:

1. Understand the Principles of Effective State Tax Policy.
2. Analyze COST's Objective Assessment of State Administrative Practices.
3. Leverage COST's Scorecards for Legislative Initiatives.

Speaker:
Marilyn Wethekam, Esq.
Of Counsel
Council On State Taxation
Chicago, IL

Continuing Education

We have applied for 2.5 Continuing Legal Education (CLE) credit for this program (including 1.0 Ethics credit) in Minnesota.

We have also applied for 4.0 Continuing Professional Education (CPE) credit for this program (including 1.0 Ethics credit).

Advance preparation: None | Program level: Intermediate | Prerequisites: None | Delivery method: Group live | Field of study: Regulatory Ethics - 1.0 and Taxes - 3.0 | CPE: 4.0 credits.

Fredrikson & Byron, P.A. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org