Super Conference 2026

When Exam or Collection gets it wrong, Appeals is often your best shot at a fair outcome, but only if you pick the right path and file it the right way. This in-depth masterclass covers the full Appeals process, from the Taxpayer First Act and your client’s actual right to appeal, to CAP, CDP, equivalent hearings, TFRP protests, and lesser-known venues like Fast Track Settlement and Post-Appeals Mediation. Using real case examples and a sample formal protest, you’ll learn how Appeals weighs hazards of litigation, what it will and won’t consider, and how to walk into the conference prepared to settle.

Key Takeaways:

• Choose the right appeal path (CAP, CDP, equivalent hearing, or formal protest) and know which ones protect your client’s Tax Court rights.
• Meet critical deadlines and prepare formal protests that satisfy Publication 5 and hold up in Appeals.
• Use hazards-of-litigation settlements, case file access, and new evidence strategically to improve outcomes.
• Know your options when Appeals says no, including Tax Court, mediation, and other alternative venues.

Sometimes the biggest threat in a case isn’t the liability. It’s an IRS employee who doesn’t know the law, the procedure, or how the case should be worked. In this practical session, you’ll learn how to spot when the IRS has gone off track, protect your client’s rights, and steer the case back toward the right resolution. We’ll walk through a real high-dollar payroll tax case assigned to a brand-new Revenue Officer unfamiliar with Trust Fund Recovery Penalty investigations, where the IRM and some creative advocacy kept the client out of harm’s way.

Key Takeaways:

• Recognize procedural missteps, incorrect standards, and improper enforcement actions before they damage your client.
• Use the Internal Revenue Manual strategically to redirect inexperienced or misinformed IRS personnel.
• Know when to educate, when to escalate, and when to challenge the IRS position outright.
• Build documentation and advocacy strategies that hold up in high-risk payroll tax and collection cases.

Some cases can’t be resolved, because the client is the problem. This session is a detailed case study of a messy, emotional collection case that spanned more than a decade. It involved multiple past businesses, prior representatives, and six Offers in Compromise on the same periods, with one still in Appeals. You’ll see why the case looked winnable despite early warning signs, what it took to get up to speed as the new representative, and how it ended in a withdrawal when the clients refused to comply. You’ll leave knowing the red flags that tell you it’s time to walk away, even when you want to solve the problem.

Key Takeaways:

• Get up to speed fast on a collection case already in Appeals, including why you must pull the TXMODA to track multiple tolling events.
• Recognize the red flags, from both the IRS and the client, that signal a case can’t be resolved.
• Know when a client’s refusal to comply leaves you no choice but to withdraw as POA, and how to terminate properly with the right documentation.
• Use well-drafted engagement letters to define scope and responsibilities on both sides, and know when to refer out cases involving people you know personally.

No script, no filter, just two seasoned practitioners talking through the tax law and case issues that come up in real resolution work. This open, candid session covers key IRC provisions, recent IRM changes, new case law on innocent spouse and TFRP matters, and practical procedures for exams, collections, Appeals, and docketed cases. You’ll also hear the presenters’ real “case battle stories,” both the wins and the losses, and what each one taught them. You’ll walk away with practical strategies you can apply to your own cases right away.

Key Takeaways:

• Apply key Code provisions in practice, including your client’s representation rights at IRS interviews under IRC §7521(c) and civil fraud penalty exposure under IRC §6663.
• Understand recent changes to IRM 5.1.15 and the practitioner concerns around Policy Statement P-5-133.
• Stay current on recent case law developments in innocent spouse relief and TFRP matters.
• Learn from real wins and losses across exams, collections, Appeals, and docketed cases.

When a case goes sideways, it’s not always clear whether to send it to the Taxpayer Advocate Service, file a CAP, or escalate another way. Worse, you can file a Form 911 only to have it bounced back as “not a TAS case.” This session covers which cases TAS will accept, which it won’t, and how to tell the difference before you file. You’ll learn how to spot a TAS-ready case and improve your odds of getting an advocate assigned.

Key Takeaways:

• Identify which cases meet TAS acceptance criteria, and which ones TAS will turn away.
• Decide when to go to TAS, when to file a CAP, and when another escalation route will work better.
• Prepare a Form 911 that clearly shows hardship or systemic failure so it doesn’t get kicked back.
• Get TAS attention on your case faster and keep it moving once it’s accepted.

Revenue Officer cases can escalate fast when deadlines tighten, levies are threatened, and your client is panicking. This session gives you real-world strategies for handling high-pressure RO interactions while protecting your client, keeping your credibility, and avoiding reactive mistakes that make a case worse. You’ll learn how to tell genuine seizure risk from negotiation pressure, handle wage and bank levy exposure calmly, and keep control when an RO’s direction keeps shifting.

Key Takeaways:

• Respond strategically to aggressive RO communications, and recognize real enforcement risk versus standard pressure tactics.
• Manage wage levies, bank levies, and garnishment exposure without overreacting.
• Stay in control when a Revenue Officer changes direction or contradicts earlier guidance.
• Document cooperation and compliance in a way that builds credibility without revealing your case strategy.

High income, even higher lifestyle, and an IRS balance north of $250,000: these are some of the toughest resolution cases you’ll handle. This session shows you how to evaluate and structure Partial Pay Installment Agreements for high-income taxpayers, including how proximity to the CSED changes your strategy and leverage. You’ll learn how CDP rights and Notices of Determination can slow enforcement and strengthen your position, how to use seasonal or declining income to your advantage, and when to bring in TAS. Real case studies show what works, what doesn’t, and how to manage clients who don’t fully grasp how serious their situation is.

Key Takeaways:

• Determine when a PPIA fits a high-income taxpayer, and how the CSED shapes your negotiation and long-term plan.
• Use CDP rights and Notices of Determination to slow enforcement and preserve your options.
• Time your financials around seasonal or declining income, and know when Form 911 and TAS are the right move.
• Set clear client expectations so they see you as the good guy, and learn from real high-liability PPIA cases.

Your technical skill only helps if clients trust it, and in tax resolution that trust is won or lost in high-pressure conversations. TEDx speaker, executive coach, and bestselling author Mike Acker shows you how to close the gap between being competent and being seen as competent. Using his Executive Presence framework adapted to real tax resolution scenarios, you’ll learn to communicate with clarity, confidence, and authority when clients are stressed, fees are on the table, and the stakes are high. It’s practical and interactive, and you’ll leave with tools you can use in your next client call.

Key Takeaways:

• Close the “Presence Gap” between your actual expertise and how clients perceive it.
• Apply the Aware → Know → Practice → Feedback framework to sharpen how you communicate.
• Speak with clarity and authority in fee conversations and with stressed or uncertain clients.
• Use three core skills that immediately strengthen your presence and position you as a trusted advisor.

A case can end well and still be miserable to live through. The IRS already brings plenty of delays and unanswered questions, so your firm shouldn’t add its own. This session covers the workflows and systems that keep cases moving, keep clients informed, and stop you from being the most overworked case-management software in the office. You’ll learn to build SOPs for cases that refuse to follow the SOP, track status without an office-wide scavenger hunt, and schedule follow-up before a client’s “just checking in” email does it for you.

Key Takeaways:

• Build repeatable SOPs and templates that hold up when a case goes sideways.
• Track status, deadlines, and next steps so your caseload lives in a system instead of your head.
• Give every next action a clear owner, and catch stale cases before your clients do.
• Keep clients informed and confident, even when the IRS gives you nothing new to report.

Every AI research tool promises faster answers and better research, but which ones actually hold up in tax resolution work, and which ones give you confident wrong answers? This session puts today’s leading AI and tax research tools head-to-head on real IRS problems involving collections, penalty abatement, appeals, payroll tax, and procedural disputes. You’ll see how each platform does on accuracy, citations, handling of the IRM and IRC, hallucination risk, ease of use, and cost. You’ll leave knowing which tools are worth the money and how to use them without putting your clients or your license at risk.

Key Takeaways:

• Compare leading AI research tools on accuracy, citation quality, and real-world value for representation work.
• Spot hallucinations and unsupported conclusions before they end up in your client’s case.
• Verify AI-generated answers against the IRC, IRM, and other primary authority.
• Build a safer, more efficient research workflow and choose the tools that fit your practice and budget.

Bankruptcy can change every resolution option on the table, but most practitioners never learn how it actually works. This session takes bankruptcy out of the textbook: Kathy explains what it is and how it works in plain English, and a bankruptcy attorney translates what the legal terms really mean. You’ll then walk through a real case that went badly wrong, with the actual numbers, the decisions that were made, and what should have been evaluated differently. You’ll leave knowing when bankruptcy deserves a closer look, how to work alongside a bankruptcy attorney, and where tax resolution work ends and the practice of law begins.

Key Takeaways:

• Understand what bankruptcy is and how it works, in both plain and legal terms.
• Recognize when bankruptcy may open up or change a client’s resolution options, and why the analysis should come before you pick a strategy.
• Know what you can evaluate and discuss with clients without crossing into the practice of law, and when to bring in bankruptcy counsel.
• Learn from a real case gone wrong, with the actual math, and what could have been handled differently.

Many business owners think they’re operating as one type of entity while the IRS sees something else entirely, and the fallout can be costly for both client and practitioner. A missing S election, a partnership filing as an S corp, an accidental C corporation, or an ownership change that quietly altered entity status can lead to years of improper filings, payroll problems, and serious tax exposure. This session shows you how to figure out what the IRS actually recognizes, using formation documents, transcripts, election acknowledgments, payroll filings, and prior returns. Through real-world case studies, you’ll learn practical resolution strategies and how to decide whether a distressed business should be cleaned up, restructured, or dissolved.

Key Takeaways:

• Run a diagnostic review to find gaps between a business’s intended entity treatment and its actual IRS classification.
• Resolve common mismatches, including missing S elections, partnerships filing as S corps, accidental C corporations, and single-member LLC issues.
• Evaluate whether a cleanup is realistic and defensible, or whether the business should be restructured or dissolved.
• Manage client expectations and reduce your own preparer exposure in complex entity compliance cases.

When “for better or worse” turns into “jointly and severally liable,” innocent spouse relief may offer a way out. Miami tax attorney Steven Klitzner will show you how to work through the three avenues of relief under IRC §6015 and recognize which one fits the facts. From Form 8857 through Appeals and Tax Court, Steve will focus on the practical issues that can make or break an innocent spouse case. You’ll leave knowing how to spot these cases, develop the right facts, and build a stronger claim for relief.

Key Takeaways:

• Understand the three avenues of relief under IRC §6015 and match the right one to your client’s facts.
• Spot qualifying clients early and ask the questions that uncover the facts and documents that matter.
• Handle the process from Form 8857 through IRS Appeals and Tax Court.
• Avoid the common mistakes that sink innocent spouse claims, and present a stronger case for relief.

Most firms have plenty of ideas. What they lack is clarity about which one matters. In this closing session, we’ll look at one question that shows what is holding your firm back and where your time, money, and attention should go over the next 12 months. Your goal might be more revenue, more freedom, a stronger team, or a better business. Either way, the answer can change what you work on next. You’ll stop chasing every new strategy, tool, and marketing trend, and go after the one thing your firm needs right now.

Key Takeaways:

• Use a simple framework to find what’s limiting your firm’s growth.
• Stop spending time and money on problems that aren’t your biggest problem.
• Judge new ideas, technology, marketing, and hiring decisions against that one priority.
• Leave with a specific focus for 2027 and a better way to decide what gets your attention next.

Out there, they don’t get it.

They don’t understand how we can get excited about an event on taxes.
How we talk shop at dinner like it’s a thriller novel. How solving a gnarly IRS issue lights us up more than a beach vacation.

But in here—you’re among your people.

People who see what you see. Who obsess over the details. Who light up over case law. Who know what it feels like to carry someone else’s burden until you lift it.

Here, no one asks you to explain why you care so much.
We already know.

This isn’t just another CPE conference.

It’s a return to the place where your passion is understood—where your commitment is shared, and your curiosity is matched.

Where every conversation reminds you: you’re not alone in how deeply you care.

At Super Conference – You’re exactly where you’re supposed to be.