Super Conference 2023

One of the driving forces behind our significant impact in the tax resolution industry is the shared vision and dedication of our leadership, team, and members. We’re not just another membership; we’re a community. Together, we’re always on the lookout for opportunities to grow, to enhance our skills, and to stay informed about the latest updates. Our ultimate goal? To confidently and effectively uphold our clients’ rights.

The past year has been particularly eventful. The IRS has sprung back into action, expanding its workforce and introducing new tools and opportunities, along with fresh challenges. On top of that, we’re at a pivotal moment in history as AI technology becomes accessible to small firm owners and the IRS alike. There’s so much to unpack and discuss. Let’s journey through these changes together and ensure we’re at the forefront of the industry.

Presented by Larry Lawler, CPA, EA, CTRS

“Mastering IRS Refund Claims” is a seminar session designed to demystify the complexities of the IRS refund claims process. After this session participants will understand the importance of time constraints, the implications of extensions, how to distinguish between tax payments versus deposits, and much more.

Larry will explore the nuances of protective and informal claims, identifying appropriate courts for refund suits, and learn about potential IRS actions. Attendees will emerge better equipped to handle refund claims with confidence, precision, and informed strategy.

Key Learning Outcomes from the Program:

1.  Claims Processes: Understand the key timelines, implications of extensions, and strategic nuances of filing IRS refund claims.
2. Claim Types & Legal Venues: Differentiate between various claim types, including protective and informal claims, and identify the appropriate courts and procedures for refund suits.
3. Analytical Insights: Distinguish between tax payments and deposits and recognize the conditions and methods for IRS refund rectifications.

Presented by Steve Klitzner, Esq., CTRS

Finally. An Offer in Compromise presentation that is not about Doubt as to Collectability! This is about the other Offers. Miami Tax Attorney Steven Klitzner will identify those cases where the taxpayer can make a deal for less than their reasonable collection potential with Effective Tax Administration or Special Circumstances.

Steve, an expert in the field, will guide attendees meticulously through the process of a ‘Doubt as to Liability Offer.’ This step-by-step walkthrough aims to equip participants with the knowledge and skills to significantly reduce their client’s outstanding IRS debt.

Key Learning Outcomes from the Program:

1. Gain a comprehensive understanding of the scenarios where your client might qualify for an Offer in Compromise under the Effective Tax Administration or Special Circumstances.
2. Acquire the expertise to effectively prepare for, and ensure success in, negotiations involving the Effective Tax Administration or Special Circumstances.
3. Learn the precise timing and strategies to confidently submit and achieve a favorable outcome with an Offer in Compromise when there’s a Doubt as to Liability.

Presented by Michael Sardar, JD

Navigating the complexities of tax compliance can be challenging, especially for those who have previously deviated from their obligations. The IRS’s voluntary disclosure practice serves as a beacon of hope, offering a structured route for such taxpayers to rectify their past oversights and return to full compliance.

This course delves deep into the IRS’s voluntary disclosure practice, which is designed not just for those who made innocent mistakes, but also for individuals whose actions were willful, fraudulent, or even bordered on criminality. By leveraging the IRS’s voluntary disclosure practice, taxpayers can shield themselves from potential criminal prosecution and significantly reduce the civil penalties that might otherwise be levied against them.

Key Learning Outcomes from the Program:

1. Understanding the Context: Recognize the specific situations and scenarios where opting for a voluntary disclosure becomes a prudent choice, ensuring that taxpayers can make informed decisions.
2. Eligibility Criteria: Delve into the specifics of who can leverage the voluntary disclosure practice. This segment will help participants classify and determine the eligibility of taxpayers, ensuring that they can guide their clients or organizations effectively.
3. Application Process Demystified: Gain a thorough understanding of the step-by-step process involved in applying for the IRS’s voluntary disclosure. From the initial stages of application to the final steps of completion, this course will provide a comprehensive outline, ensuring that participants are well-equipped to navigate the procedure with confidence.

Presented by Angelene Wierzbic, EA, CTRS

It’s not uncommon for taxpayers to seek professional assistance only after they find themselves deeply mired in audit complexities. Sometimes, they might have initially sought guidance from a preparer who, upon realizing the depth of the situation, advises the taxpayer to seek more specialized help.

For tax representatives, this often means diving into a case without a clear picture of prior interactions, decisions, or potential missteps. This lack of clarity can be a significant hurdle. However, with the strategic use of tools like the Freedom of Information Act (FOIA) and Disclosure Rules, representatives can gain access to crucial historical data and case information. This course aims to equip participants with the knowledge and skills to effectively utilize these tools, bridging the information gap and ensuring a more informed approach to ongoing audits.

Key Learning Outcomes from the Program:

1. Introduction to FOIA and Disclosure Requests: Gain a foundational understanding of what these requests entail and their significance in the context of tax audits.
2. Distinguishing FOIA from Disclosure Requests: Delve into the nuances that differentiate these two types of requests, ensuring that you can select the most appropriate tool for your specific case needs.
3. Strategic Timing: Learn the art of timing your requests optimally to maximize the benefits and ensure timely access to essential information.
4. Essential Documentation: Understand the critical items that must be present in your file when making these requests, ensuring that your applications are comprehensive and effective.
5. Preparation for Appeals: Discover how the information gleaned from these requests can be instrumental in preparing for potential appeals, equipping you with a robust defense strategy.
6. Real-world Scenarios: Angelene shares compelling “war stories” from her extensive experience, illustrating how seemingly straightforward FOIA requests can dramatically alter the trajectory of a case.

Presented by LG Brooks, EA, CTRS & Angelene Wierzbic, EA, CTRS

The submission of an “Offer-in-Compromise” (OIC) mandates that taxpayers disclose & document either all “monthly household income” or “monthly business income & receipts” based upon the type OIC being submitted to the Internal Revenue Service (IRS) for review & consideration.  However, based upon my personal experience and based upon my discussion with various other tax practitioners, the calculation or determination of “what constitutes gross monthly income for OIC purposes” varies significantly based upon the decisions & responses issued by IRS Offer Specialist and Offer Examiners.

This presentation is designed to discuss, explore, explain and demonstrate “how to calculate gross income for OIC purposes” by disclosing the applicable legal guidelines & appropriate administrative procedures related to what constitutes “income” for OIC purposes and furthermore, what does not constitute income for OIC purposes.

Key Learning Outcomes from the Program:

1. How to “identify” and classify disclosable income for OIC purposes
2. How to calculate identifiable income for OIC purposes
3. How to justify or substantiate your OIC income position
4. How to respond to an OS or OE regarding a “disputable” income issue
5. How to challenge an inappropriate OS or OE decision related to OIC income
6. How to incorporate legal authority in your response to enhance your OIC income position

This presentation will also include “hands-on” interactive demonstrations of various OIC income calculations & descriptions of “what-is”, “what-is not” & “what shouldn’t be” OIC Income.  It will include actual arguments, defenses related to the challenges raised by Brooks & Wierzbic related to this topic.

Presented by Deborah Weber, Esq.

Understanding the nuances of the Employee Retention Credit (ERC) is paramount for both businesses and tax professionals. This comprehensive session is tailored to provide participants with an in-depth exploration of the ERC.

Beginning with a clear delineation of who qualifies for this credit, the course will guide attendees through the intricacies of claiming the ERC. Moreover, in anticipation of potential IRS challenges, participants will be equipped with knowledge on the necessary preparatory actions, essential documentation, and best practices for retention. Should the IRS contest a claim, leading to a Notice of Disallowance, this course will also offer a roadmap on the subsequent steps to undertake.

Key Learning Outcomes from the Program:

1. Deciphering IRS Guidance: Navigate the labyrinth of IRS guidelines with ease. Learn to meticulously analyze, interpret, and apply the IRS’s Revenue Procedures and Notices. Tailor this knowledge to your client’s unique circumstances, ensuring that potential claims are both valid and advantageous.
2. Claiming the ERC – Procedural Insights: Dive deep into the procedural aspects of the ERC. Understand the best practices, potential pitfalls, and essential steps when staking a claim on behalf of your clients. This segment ensures that participants are well-versed in the technicalities, leading to smoother claims processes.
3. Beyond the Claim – Considerations and Implications: Claiming the ERC is just the tip of the iceberg. This course will shed light on the broader considerations and potential ramifications of staking a claim on behalf of clients. Whether it’s understanding the financial implications, potential risks, or the strategic benefits, participants will walk away with a holistic view of the ERC landscape.

Presented by Billy Fauller, EA, CTRS

While many professionals have encountered IRS summonses in their practice, few truly grasp the intricate procedures, protocols, and nuances that underpin these legal documents. This course seeks to demystify the world of IRS summonses, shedding light on the often-overlooked details that can be harnessed to advocate more effectively for your clients.

Dive deep into the foundational elements of an administrative summons, exploring its structure, purpose, and the legal framework that supports it. Understand the breadth and limits of what the IRS can request, and arm yourself with knowledge on how to respond appropriately. Moreover, this program will elucidate the criteria that guide summons referrals, offering insights into the IRS’s decision-making process. Importantly, participants will also be made aware of common pitfalls and errors the IRS might commit, which can render a summons void.

Key Learning Outcomes from the Program:

1. Anatomy of a Summons: Delve into the core components that constitute a summons, ensuring a comprehensive understanding of its structure and significance.
2. The Legal Backbone: Unpack the legal authority that empowers the IRS to issue a summons. Understand the legal boundaries and the implications of these directives.
3. Navigating Summons Compliance: Equip yourself with a step-by-step guide on how to respond to a summons, ensuring that you act in your client’s best interest while adhering to legal requirements.
4. Strategic Presence: Evaluate the pros and cons of accompanying your client during summons proceedings. Make informed decisions on when your presence can be advantageous.
5. Spotting IRS Missteps: Become adept at identifying common errors the IRS might make in the summons process. Learn how these mistakes can be leveraged to challenge the validity of a summons.
6. Resolving Summons Disputes: Gain insights into the avenues available for escalating and resolving disagreements related to summonses. Understand the hierarchy and the best practices for effective dispute resolution.

Presented by Gary Bluestein, Esq.

Audits can be a daunting experience for taxpayers, and as professionals, understanding the nuances of various audit issues is crucial to providing the best representation. This comprehensive course delves into some of the most pressing and hot-button topics in the realm of audits. From the intricacies of gambling income to the complexities of disputing penalties, participants will be equipped with the knowledge to tackle these challenges head-on.

Key Learning Outcomes from the Program:

1. Hot Audit Issues: Dive deep into some of the most prevalent and challenging audit issues of the day. Understand the nuances of gambling income, how it’s reported, and the potential pitfalls and challenges that can arise during an audit.
2. Disputing Penalties: Gain insights into the process, strategies, and considerations when challenging imposed penalties. Learn the criteria the IRS uses and how to effectively counteract them.
3. Protest vs. Tax Court Petition: Explore the implications of filing a protest as opposed to a Tax Court petition. Understand the differences, potential outcomes, and which avenue might be best suited for specific scenarios.
4. The 872 Extension: Delve into the pros and cons of signing an 872 extension. Understand its implications, benefits, and potential drawbacks, ensuring that you can make informed decisions on behalf of your clients.
5. Potential Criminal Referrals: Discuss the red flags and concerns in cases that may escalate to a criminal referral. Equip yourself with strategies to mitigate risks and navigate these sensitive situations.
6. Post-Audit Strategy: The audit might be over, but the journey isn’t. Learn how decisions made during the audit can influence the collection phase of representation. Equip yourself with strategies to ensure that your client is positioned favorably for the post-audit phase, minimizing liabilities and maximizing opportunities for favorable outcomes.

Presented by Hank Kea, Director Field Collection SBSE & Gwanette Claybrook, Direction Collection Gulf States

Stay ahead of the curve with this comprehensive session dedicated to the latest updates in IRS collections. As the landscape of tax collections continually evolves, it’s imperative for professionals to be equipped with the most current information and strategies. Hank Kea and Gwanette Claybrook, both esteemed directors in their respective IRS collection fields, come together to provide attendees with a deep dive into the recent changes, trends, and best practices in IRS collections.

Key Learning Outcomes from the Program:

1. Recent Changes: Understand the latest modifications in IRS collection policies and procedures, ensuring you’re always up-to-date.
2. Emerging Trends: Hank and Gwanette will shed light on the emerging patterns in collections, helping attendees anticipate and prepare for future shifts.
3. Best Practices: Equip yourself with the most effective strategies and tactics in navigating the IRS collection process, straight from the experts.

Presented by Kim Stewart – Deputy Taxpayer Advocate

In the intricate world of IRS representation, the Taxpayer Advocate Service (TAS) plays a pivotal role in ensuring that taxpayers receive fair and just treatment. As professionals dedicated to representing taxpayers, understanding how to seamlessly collaborate with the TAS can significantly enhance the outcomes of your cases.

Kim Stewart, with her esteemed position as the Deputy Taxpayer Advocate, brings to the table a wealth of knowledge and firsthand experience. In this course, she will shed light on the inner workings of the TAS, offering invaluable insights into how IRS representation professionals can forge a productive and harmonious relationship with the service.

Presented by Anton Collins, Esq.

The IRS Automated Under Reporter (AUR) Exams can often seem like a daunting and intricate process for many tax professionals. However, with the right knowledge and approach, representing clients in these situations can be both straightforward and efficient. This course aims to shed light on the AUR Exams, particularly focusing on the IRS CP2000 Notice, and offers a clear roadmap to achieving favorable outcomes without unnecessary complexities.

Key Learning Outcomes from the Program:

1. Understanding AUR Exam Fundamentals: Delve deep into the basic rules governing AUR Exams. Equip yourself with a foundational understanding that will guide all subsequent actions and decisions.
2. Decoding the CP2000 Notice: The IRS CP2000 Notice is a pivotal document in the AUR Exam process. Learn to interpret its contents accurately, ensuring you can advise your clients with clarity and confidence.
3. Identifying Common AUR Cases: Not all AUR Exams are created equal. Understand the most frequent scenarios and the typical triggers that lead to these cases, allowing for quicker diagnosis and action.
4. Analysis and Substantiation: Discover the art of swiftly determining the necessary analysis and gathering the right substantiation to bolster your client’s position. This segment will provide practical tools and techniques to ensure your case is built on solid ground.
5. Crafting the Perfect Response: It’s not just about responding; it’s about responding effectively. Learn to efficiently draft a comprehensive response to the IRS, ensuring it addresses all pertinent issues and paves the way for a fair and accurate exam outcome.
6. Templates and Language: Benefit from tried and tested response templates tailored for AUR Exam cases. Additionally, understand the specific language and terminology that resonates best with the IRS, enhancing the persuasiveness of your communications.

Presented by Mitchell Piper, ASTPS Director of Marketing

The rapid evolution of artificial intelligence, particularly the emergence of tools like ChatGPT, has transformed various sectors, including tax resolution. This course delves into the practical applications of AI and ChatGPT in managing and resolving tax-related issues, especially in the context of IRS representation. By integrating these advanced tools, tax professionals can streamline processes, enhance client communication, and achieve more favorable outcomes with efficiency.

Key Learning Outcomes from the Program:

1. Introduction to AI in Tax Resolution: Gain a foundational understanding of how artificial intelligence is impacting the tax industry
2. Practical uses of AI in your practice: Learn specific workflows that can help you save huge amounts of time in your day. Find out how tools like ChatGpt can help you communicate with clients, write marketing pieces, creates letters, and more!
3. Cut through the confusing amount of tools available: There are dozens of new AI tools created every day! We’ll point out a few you should be playing with.
4. Future of AI in Tax Resolution: Look ahead to the evolving landscape of tax resolution in the age of AI. Understand the potential challenges, ethical considerations, and the roadmap for integrating more advanced AI tools in the coming years.