Villanova University School of Law 299 N. Spring Mill Road, Villanova, PA (610) T.

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1 T. Keith Fogg Villanova University School of Law 299 N. Spring Mill Road, Villanova, PA (610) EMPLOYMENT Villanova University School of Law, Villanova, PA Visiting Associate Professor of Law, Associate Professor of Law, Professor of Law, 2011-Present Director, Federal Tax Clinic, January 2008 Present Visitor at Harvard Law School for academic year Internal Revenue Service Office of Chief Counsel Senior Counsel, Associate Area Counsel, Richmond, District Counsel, Richmond, Chief, Branch 1, General Litigation Division, Docket Attorney, (Special Assistant United States Attorney in Eastern and Western Districts of Virginia, ) Georgetown University School of Law, Washington, D.C. Adjunct Professor, University of Richmond School of Law, Richmond, VA Adjunct Professor, College of William and Mary School of Law, Williamsburg, VA Adjunct Professor, 1996 Virginia Commonwealth University, Richmond, VA Adjunct Professor University of Arizona School of Law, Tucson, AZ Visiting Professor 1987

2 EDUCATION College of William and Mary School of Law M.L.T, 1982 University of Richmond School of Law J.D., 1977 College of William and Mary B.A., 1974 PUBLICATIONS Academic Articles History of Low Income Taxpayer Clinics, 67.1 Tax Lawyer 3 (2013). Financial Disability for All, 62.4 Catholic University Law Review 965 (2013) (with Rachel Zuraw). Go West: How the IRS Should Foster Innovation in its Agents, 57.3 Villanova Law Review 441(2012). Transparency in Private Collection of Federal Taxes, Florida Tax Review 763 (2011). In Whom We Trust, 43.2 Creighton Law Review 357 (2010). Leaving Money on the Table and Providing An Incentive Not to Pay, 5.1 Hastings Business Law Journal 1 (2009). Practice Articles Does the Failure to Timely Issue Notice and Demand Impact the Underlying Assessment Rather Than Just Liens and Levies? Vol. 16, No. 2, p. 23 Journal of Tax Practice & Procedure (2014). What is a Return The Long Slow Fight in Bankruptcy Courts Vol. 15, No. 5, p. 37 Journal of Tax Practice & Procedure (2013). Systemic Problems with Low-Dollar Lien Filing, 133 Tax Notes 88 (2011). Tax Court Collection Due Process Cases Take Too Long, 130 Tax Notes 403 (2011)(with Carl Smith)

3 Collection Due Process Hearings Should Be Expedited, 125 Tax Notes 919 (2010)(with Carl Smith) National Tax Lien Registry, 120 Tax Notes 783 (2008). Amended Returns- Imposing a Duty to Correct Material Mistakes, 120 Tax Notes 979 (2008)(with Calvin Johnson). Books Blog Effectively Representing Your Client Before the New IRS. Published by ABA Tax Section. Editor of 5 th Edition published in January 2012; Editor of 6 th Edition published in February 2015; Author of Chapter updates of 10 and 13 for the 4 th Edition published in 2009; Author of Chapters 11 and 12 for the 5 th Edition; Author of Chapter updates of Chapters 11, 12 and 21 in 6 th Edition IRS Practice and Procedure by Saltzman and Book. Published by Thompson and Reuters. Author of Chapter 16 update in Author of Chapter 14 and 15 updates to be published in 2015; Author of Chapter 14A to be published in 2015 Enforcement of Liens and Judgments in Virginia Published by Virginia CLE Publications. Author of Chapter 8 for the 5 th Edition published in 2004 and update of Chapter 8 for the 6 th Edition published in 2009 Co-founder in 2013 of Procedurallytaxing.com with Professor Les Book and Steve Olsen. The blog focuses on tax procedure issues seeking to provide analysis of cases and rulings that impact federal tax procedure. The blog posts an article almost every work day written by one of the three founders or a guest. In addition to the stand alone blog cite, we occasionally post on the Forbes blog network of which we are a member. ACADEMIC PRESENTATIONS Commenter at Duke Law Review Symposium, (Un)Appealing Deference to the Tax Court February, 2014 Moderator at Villanova Law Review Symposium panel, Offshore Compliance and Collection September 2011

4 NON-ACADEMIC PRESENTATIONS American Bar Association Tax Section regular presenter since 2008 and occasional presenter since 1998 before Pro Bono and Tax Clinic Committee, Individual Income Tax Committee, Bankruptcy and Tax Committee, Administrative Practice Committee Department of Justice National Advocacy Center Advanced Bankruptcy Program, regular instructor from 1997 through 2007 Internal Revenue Service National Taxpayer Advocate Annual LITC Conference, regular presenter since 2006 Chief Counsel Training Programs on Bankruptcy and Collection, regular presenter from 1986 to 2006 GRANT WRITING Primary drafter of grant proposal to the United States Department of Treasury to fund Villanova Law School Federal Tax Clinic from 2008 to present. Administer the program and primarily responsible for Law School compliance with Treasury grant guidelines, including the preparation and submission of interim and final reports. Drafted grant proposal to the Community Tax Law Project to fund Villanova Law School Tax Court Trial Training program. Designed a trial practice course to train lawyers and students how to litigate a case in the United States Tax Court. The course teaches students in Villanova s Graduate Tax Program how to handle a low income tax case to promote their acceptance of pro bono cases upon graduation. Villanova has made the course a regular part of its graduate tax curriculum since 2008 and invites any clinician to attend for a nominal fee. Jointly drafted, with another low income tax clinic, a proposal to the United States Tax Court to prepare a script for the Court to explain to low income taxpayers how a Tax Court case proceeds. Prepared the initial draft of the script in fall 2007 and participated in working with the Court to make requested revisions to the draft. The script was adopted into the web page tab for Taxpayer Information on the Tax Court s homepage. COURSES TAUGHT Tax Practice & Procedure University of Arizona Law School 1987 Virginia Commonwealth University Villanova Law School, Present Tax Exempt Organizations University of Arizona Law School 1987

5 Federal Taxation of Bankruptcy and Workouts Georgetown Law Center, 1992 to 2006 William & Mary Law School, 1995 Basic Income Tax University of Richmond, 1995 and 1996 Federal Tax Clinic Tax Court Trial Training Villanova Law School, Present Villanova Law School, 2008 (consulting thereafter) SERVICE Professional AWARDS Chair, ABA Pro Bono and Tax Clinic Committee 2011 to 2013 ABA Tax Section, Council 2014 to present Robert H. Jackson, Attorney of the Year 2007, Office of Chief Counsel, Internal Revenue Service Janet Spragens Pro Bono Award 2015, ABA Section of Taxation BAR ADMISSIONS Admitted to practice in Pennsylvania and Virginia (currently a non-practicing member) Admitted to practice before the United States Tax Court Admitted to practice before the Eastern District of Pennsylvania and Third Circuit