2023 IRS Representation: Audits, Penalty, Abatement, Litigation, and Collection Alternatives

June 27, 2023
240 Mins
Adam Fayne
IRS CPE Credits: 3 Tax hour
$399.00
$449.00
$449.00
$499.00
$449.00
$399.00
$449.00
$399.00
$399.00
$449.00
$449.00
$399.00

All prices mentioned above are for single user access only. For multi-user access, kindly call us on (818) 584-2346 or email us at cs@grcsolutionz.com

Session I- 2023 Internal Revenue Service Updates 

The Internal Revenue Service changes and announces new initiatives every year. This webinar will discuss the Internal Revenue Service’s latest initiatives and how you can prepare for a successful year in representing your clients. We will discuss the Internal Revenue Service’s audit and collection efforts and activities and what you can expect during 2023 with an Internal Revenue Service that may have its first large budget increase in more than a decade.

Learning Objectives:

This webinar will provide insight and tools to assist you and your clients understand what the Internal Revenue Service will focus on during 2023 and how successful they were during 2022.  We will discuss what a large budget increase to the Internal Revenue Service will mean for taxpayers

Session Highlights:

  • IRS Audit Activity during 2022
  • IRS Collection Activity during 2022
  • IRS priorities for 2023
  • IRS Budget and what it means for your client
  • New Programs that may be beneficial to your client

Session II- IRS Nonfiler Representation – Representing Taxpayers that have not filed Tax Returns

This webinar will focus on representing taxpayers that have not filed tax returns. We will discuss unfiled returns by individuals and entities. This program will discuss how to address unfiled income tax returns, employment tax returns, Foreign Bank Account Reports, and other domestic and foreign information returns. We will discuss best practice when representing taxpayer with unfiled returns, including how many years or periods to file, what disclosures to include, whether there are voluntary disclosure programs available, and how to minimize or abate penalties.

Learning Objectives:

This webinar will provide insight and tools to assist you and your clients understand the various ways to address unfiled returns. You will learn how to prepare and file a reasonable cause statement with the unfiled returns to try and avoid penalties. You will also learn how to try and abate penalties due to the taxpayer’s unfiled and late returns. We will also discuss how to address unfiled returns during audits, collections, and criminal investigations.

Session Highlights:

  • The available processes to file unfiled returns
  • Contesting penalties assessed or proposed related to the unfiled returns
  • How to put forth a reasonable cause defense to penalties
  • Civil versus criminal risk with unfiled returns
  • How to address unfiled domestic and foreign information returns

Session III- Penalty Abatement Requests and Litigation: 2023 Updates

The IRS asserts millions of dollars in tax penalties against taxpayers each year. This webinar will teach you how to represent your client and seek abatement and removal of IRS penalties. You will learn about Reasonable Cause exceptions to penalties, the First Time Penalty Abatement procedures, various methods to request penalty abatement (e.g. in exam, appeals, post-appeals, Collection Due Process), and how to litigate penalty abatement requests when you are unsuccessful in the examination, administrative, or appellate stage. We will also discuss the various types of penalties that the IRS may assert against your client.

Learning Objectives

This webinar will provide insight and tools to assist you and your clients understand what penalties may be asserted if certain actions are taken, or not taken. You will learn how to dispute penalties at the various stages of a penalty lifecycle; e.g. examination stage, appellate stage, collection stage, and refund stage. Lastly, you will learn about the ability to dispute penalties administratively and through formal litigation in Tax Court and District Court.How and why is the notice defective?

Session Highlights:

  • The various penalties the IRS could assert against a taxpayer, including penalties related to foreign assets.
  • Contesting Penalties in Examination
  • Contesting Penalties in Appeals
  • Contesting Penalties in Collection Due Process
  • Contesting Penalties in Tax Court
  • Contesting Penalties in District Court
  • Automatic vs Discretionary Penalties
  • Reasonable Cause exception to Penalties

Session IV- IRS Collection Alternatives – Payment Plans, Offers In Compromise, and more 

The Internal Revenue Service provides several options when a taxpayer needs assistance paying a tax debt, or cannot pay at all. This program will discuss the various options available to taxpayers. Those options include payment plans, currently not collectible, and Offers in Compromise. Practitioners need to understand these various options so they can best advise their clients on what collection alternative is appropriate for their situation. Not every taxpayer is eligible for a payment plan or an Offer In Compromise. We will discuss how to approach the IRS, the strategies involved, and the required (and not required) financial statements and information to provide to the IRS.

Learning Objectives:

This program will provide insight and tools to assist you and your clients understand how to secure a collection alternative from the IRS – Payment Plan, Offer In Compromise, or Currently Not Collectible Status.

Session Highlights:

  • Overview of IRS Collection Process
  • IRS Payment Plans
  • IRS Offers In Compromise
  • Currently Uncollectible Status
  • Financial Disclosures
     

Note: This is a combo of 4 Webinars (each with a 60-minute duration)

Credit(s)
IRS CPE Credits: 3 Tax hour

Adam Fayne

Adam Fayne

Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white-collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money laundering, and offshore tax compliance. Adam's knowledge of tax law is informed by his former role as a Special Assistant U.S. Attorney with the Department of Treasury's IRS.
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