Penalty Abatement Requests and Litigation

October 20, 2021
01:00 PM ET | 12:00 PM CT
60 Mins
Adam Fayne

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.

Webinar 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.
Webinar 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
  • Financial Compliance Professionals
  • lawyersa
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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