IRS Representation, Audits and Penalty Abetment Updates

September 01, 2021
240 Mins
Robert E. McKenzie & Adam Fayne
$399.00
$449.00
$449.00
$499.00
$449.00
$399.00
$449.00
$399.00
$399.00
$449.00
$449.00
$399.00

Session 1 - 2021 IRS Representation Update

Speaker -  Robert E. McKenzie
Duration - 120 Min

COVID-19 dramatically changed IRS enforcement procedures. In July 2020 the IRS reactivated its enforcement activities after 4 months of no enforcement activity. Since that time it has gradually increased its enforcement presence. This webinar by industry expert Robert McKenzie will provide a timely update of IRS initiatives and procedures. IRS can be expected to return to its prior tough enforcement approach.

Over the past several years, the IRS has seen its budget cut significantly. There has been a corresponding reduction in the quality of service that it provides, including a dramatic cutback in its enforcement efforts. 2019 was a turning point for IRS. It was able to hire 1,000 new enforcement professionals. The new IRS commissioner is improving morale at the agency. This course will examine the methods of the IRS COVID enforcement climate. It will cover new IRS examination and collection priorities and procedures, IRS criminal investigation initiatives, recent important developments for practitioners, and taxpayer advocate services. Other topics to be discussed include problems in the tax system, new procedures at IRS campuses, and the impact of new IRS leadership. This course is certain to get you up to speed on how to properly advise your clients in this new enforcement environment.

Session Objectives

Upon successful completion of this course, participants will be able to:

  • IRS COVID-19 initiatives
  • Identify IRS initiatives in examinations
  • Recognize current changes in IRS collection procedures including easily secured installment agreements for taxpayers who owe less than $250 K.
  • Identify the IRS offshore compliance initiatives
  • Recognize IRS budget problems and its impact on your clients
  • Discuss IRS penalty procedures and analyze common IRS penalties
  • Negotiating by phone with IRS Enforcement personnel

Session Highlights

  • New exam rules
  • New collection initiatives
  • Using Taxpayer Advocate
  • Service center closings
  • IRS enforcement priorities

Session 2 - IRS Audits and Appeals

Speaker -  Adam Fayne
Duration - 60 Min

This webinar will provide an update of current IRS exam and settlement initiatives and procedures. Taxpayers have increasingly needed to seek the assistance of the IRS Appeals Division due to their inability to obtain a satisfactory result at the examination stage. Taxpayers who are audited usually have a right to appeal any determination by an examination agent. Taxpayers also enjoy the right to appeal certain IRS collection enforcement actions, including seizures and liens

Session Objectives

This webinar will provide insight and tools to assist your client to navigate audits that are both routine and may have a criminal or fraud element.  You will learn how to respond to Information Document Requests, how to engage the auditor, how to navigate the delicate balance was fraud is involved, and how to exercise your rights to appeal an unsatisfactory audit determination to the IRS Office of Appeals or the US Tax Court.

Session Highlights

  • How to prepare for an audit and respond to Information Document Requests.
  • How to navigate an audit when fraud is involved.
  • How to respond to a Summons request.
  • Available options when you disagree with an audit determination – Appeals, Tax Court, and District Court
  • Settlement initiatives of the IRS

Session 3 - Penalty Abatement Requests and Litigation

Date -  Wednesday, October 20, 2021
Time - 1 PM ET 
Speaker -  Adam Fayne
Duration - 60 Min

The IRS asserts millions of dollars in tax penalties against taxpayers each year. This webinar session 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, various methods to request penalty abatement, and how to litigate penalty abatement requests when you are unsuccessful in the examination or appellate stage. We will also discuss the various types of penalties that the IRS may assert against your client.

Session Objectives

  • This program 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.

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 Tax Court
  • Contesting Penalties in District Court
  • Automatic vs Discretionary Penalties
  • Reasonable Cause exception to Penalties
Who Should Attend
  • Accountant
  • Tax Preparers
  • CFOs
  • lawyers
  • Enrolled Agents
  • CPA’s
  • Financial Compliance Professionals
     
Robert E. McKenzie

Robert E. McKenzie

Robert E. McKenzie is a partner of the law firm of Saul Ewing Arnstein & Lehr LLP of Chicago, Illinois, concentrating his practice in representation before the Internal Revenue Service and state agencies. He has lectured extensively on the subject of taxation. He has presented courses before thousands of CPAs, attorneys, and enrolled agents nationwide. He has made numerous media appearances including Dateline NBC and The ABC Nightly News. He dedicates a major portion of his time to representation before the IRS. In 2017 Mr. McKenzie received the American Bar Association Civil and Criminal Tax Penalties Committee’s Jules Ritholz Award. The award recognizes McKenzie’s...
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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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