Gain a better understanding of how to substantially reduce IRS tax penalties.
There are dozens of different penalties the IRS can assert against taxpayers. The defenses to such penalties are just as varied and often ill-defined in current guidance. Practitioners are often unaware of exactly how and when to challenge various IRS penalties. This topic will help tax practitioners understand the mechanics of various penalties and how best to defend taxpayers against IRS penalties. The material explains what defenses are applicable to certain penalties, how and when to assert such defenses, and methods for negotiating a reduction in penalties at various procedural stages. IRS penalty reduction/abatement has been decreasing steadily for the past decade - practitioners must therefore execute defenses to IRS penalties with precision to be successful. This material is critical for practitioners who represent taxpayers at all stages of tax controversy, from the initial examination stages all the way through final adjudication.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Overview of IRS Penalties
- Purpose of IRS Penalties
- Survey of Types of Penalties and Location in IRC
Defenses Against IRS Penalties
- Improper Imposition, Procedural (Managerial Approval Under 6751)
- Reasonable Basis
- Substantial Authority
- Reasonable Cause
Types of Penalties
- Accuracy Related
- Underpayment
- Negligence
- Valuation
- Failure to File
- Failure to Pay
Contesting Penalties
- IRS Approach to Penalty Reduction/Abatement
- Assessable vs. Non-Assessable
- Relief During Exam
- Relief in IRS Appeals
- Relief After IRS Appeals
- OIC
- Sue for Refund
- Challenge in Tax Court
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on August 10, 2021.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Michelle Abroms Levin
Dentons Sirote
- Shareholder in Dentons Sirote’s Huntsville, Alabama office, where she is a member of the tax practice group
- Represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, and federal district court
- Experience includes a wide range of complex tax issues
- Counsels clients in tax and business planning
- Works with clients to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels
- Prior to joining Dentons Sirote (formerly Sirote & Permutt, PC), she worked as a trial attorney at the Tax Division of the Department of Justice, where she represented the United States in federal district court
Logan Chaney Abernathy
Dentons Sirote
- Associate in Dentons Sirote’s Huntsville, Alabama office and is a member of the tax practice group
- Practice focuses on tax controversy, tax litigation, and government investigations
- Has clerked for the United States Attorney’s Office for the Western District of Tennessee, the Jackson County (Alabama) District Attorney’s Office, and United States District Judge L. Scott Coogler in Tuscaloosa, Alabama
- While attending law school, she served as Editor in Chief of the Law and Psychology Review and as the Chief Operating Officer for Raise the Bar, a student-run mentoring program affiliated with the University of Alabama School of Law and Eastwood Middle School
- J.D. degree, magna cum laude, University of Alabama School of Law; B.A. degree in criminology, summa cum laude, Mississippi State University
Sidney W. Jackson, IV
Dentons Sirote
- Associate in Dentons Sirote’s Birmingham, Alabama office, he is a member of the tax controversy practice group
- Practice focuses on all phases of federal and state tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, federal district court, and state tax tribunals
- During his undergrad years, he served as president of Tau Kappa Epsilon, treasurer of the Student Government Association, and a volunteer for VITA, a free service that prepares federal and state taxes
- LL.M. degree in taxation, NYU School of Law; J.D. degree, cum laude, Samford University’s Cumberland School of Law; B.S. degree, in accounting, University of South Alabama
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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