Am I ready for the Super Conference?
The Super Conference topics will require some prerequisite knowledge of tax resolution. If you are brand new or have very limited knowledge of the industry you will be much better starting off at the ASTPS Tax Resolution Boot Camp. This year we will be running a Boot Camp along side the Super Conference in Las Vegas and attendees of the Boot Camp will be able to come to the 3rd day of the Super Conference for free!
This year we will be staying at the Harrah's Las Vegas Hotel & Casino. The room block (while it lasts) is $97 a night. Please book your room immediately to secure your room in the hotel.
The room block expires September 5th.
Address: 3475 S Las Vegas Blvd Las Vegas, NV 89109
Conference speakers & topics are subject to change.
8:10 AM - 9:50 AM | The IRM – Practice, Procedure & Policy - 2 Hours
LG Brooks, EA, CTRS
In the course of “practicing before the IRS”, practitioners are usually confronted with situations where application of the law is a critical & pertinent factor with respect to tax resolution and/or tax defense matters. However, practitioner should not discount the values & worth of the proper application of the provisions of the Internal Revenue Manual (IRM) concerning the disposition of federal tax matters.
As noted above, practitioners are faced with legal & procedural issues from Revenue Agents, Revenue Officers and at times even Appeal Officers concerning inappropriate actions, an unauthorized procedure or an inaccurate decision or determination.
This presentation is designed to discuss & demonstrate the “value” of the proper application of the provisions of the IRM pertaining to compelling the IRS release levies, withdraw federal tax liens, or even reverse an improper appeals decision. We will utilize information, documentation and determinations from recent actual tax cases that included such unlawful & contrary IRS actions, which will be conducted in an “interactive” “Harvard-Law” School type approach to achieve and provide the maximum benefit to the attendees.
Although we will discuss the application of the law, being the Internal Revenue Code (IRC), this presentation will directly & specifically address procedures, guidelines and methods to utilize based upon your knowledge or applied knowledge of the IRM to prevail regarding issues where the IRS has “abused their authority” and/or proceeded without a “sound basis in law” and/or administrative procedure.
10:10 AM - 11:50 AM | Offshore Bank Accounts - 2 Hours
Robert E. McKenzie, ESQ., EA, CTRS
The IRS has been aggressively pursuing unreported foreign accounts since 2009. This class will review:
- Review the multiple tax filing requirements for taxpayers with foreign income and assets
- Learn the filing requirement of foreign trusts/ partnerships and their beneficiaries/partners
- Find out what to do when clients who should have filed didn’t and how to correct these failures
- Reduce penalties using the IRS’s latest voluntary compliance program
- Get an overview of the IRS’s current procedures for the correction of foreign filings
- Understand penalties – and even prosecution – for unfiled forms
- How to use IRS programs to reduce penalties
1:20 PM - 4:10 PM | Advanced Federal Tax Liens - 3 Hours
Robert E. McKenzie, ESQ., EA, CTRS
The federal tax lien (FTL) attaches to all rights, title and interest of a taxpayer wherever situated. The of an FTL can cause the failure of some businesses and will always harm the taxpayer’s credit rating. During this class, you will learn the prerequisites to the creation of the lien, the methods for perfecting the lien and its impact on your client’s assets and business. You will learn methods for lessening the impact of FTL’s including non-filing of lien, release of lien, withdrawal of lien, discharge of lien, subordination and nonattachment. You will gain valuable practical knowledge for protecting your client’s rights including their appeal rights.
Know the impact of the FTL, can assert you client’s rights, be able to request non-filing of lien, be capable of applying for withdrawal, discharge, subordination, and non-attachment of liens, know your client’s litigation options.
8:10 AM - 9:50 AM | Payroll Tax Issues: W-2 or 1099? - 2 Hours
Lawrence Lawler, CPA, EA, CTRS
You may know the rules for determining the proper classification of a worker, but do you know how to calculate the exposure for additional taxes once IRS has determined a worker to be misclassified? In this session, Larry will start with the scenarios that result in the IRS making a reclassification from independent contractor to employee status. Then he will give you the options available to your employer-client – some of which offer the employer a significant savings. This is a timely topic considering the IRS’s current focus on payroll tax issues.
10:10 AM - 3:00 PM | Tax Controversies Involving Cash Businesses - 4 Hours
Frank Agostino, ESQ.
Ever popular and entertaining, Frank Agostino, returns with a timely topic of must-know importance. Representing the troubled taxpayer is often a challenge, but the difficulty of the task is compounded for cash businesses. In this session you have the opportunity to “look over the shoulder” of a recognized expert who will show you all you need to know in this contentious area; topics include:
• The books and records required to be maintained by cash businesses,
• Indirect methods of proof used by the IRS,
• Taxpayer’s defenses to arbitrary determinations,
• Best practices of income and expense reconstruction,
• The Cash-T and IRS form 4822, Statement of Annual Estimated Personal and Family Expenses,
• Employment tax & the “Off the Books” employee,
• Sales tax and unreported cash sales,
• Understanding statistical sampling,
• Best practices for the eggshell examination,
• Criminal versus civil tax investigations of cash businesses,
• The preparer’s liability for the clients unreported cash.
3:20 PM - 5:00 PM | Officers, Officers, Officers - 2 Hours
Kevin Murphy, ESQ.
Dealing with Tax Compliance Officers (Office Auditors), responding to Revenue Officers, handling Appeals Officers, and negotiating with Settlement Officers, it’s what we do. Day in, and day out. Building on 20+ years of experience on the dark side, Kevin will offer insights, tips, and techniques for dealing with the various IRS personnel we face regularly. Now that he has departed the dark side and has now joined forces with us, the defenders of troubled taxpayers, he is prepared to reveal insider secrets you must know. Of special interest will be his insights on dealing with a rogue Revenue Officer.
8:10 AM - 11:00 AM | Listen Up! The Revenue Officers’ Boss Speaks...AGAIN - 3 Hours
Darren Guillot, Director of IRS Field Collection Operations
If you missed the 2017 Spring Conference, you likely heard about a speaker that the attendees couldn’t get enough of. Luckily, he survived the Q&A session and proved his intestinal fortitude by agreeing to a return engagement! If you deal with the IRS Collection Division and Revenue Officers, you cannot afford to miss this opportunity for a second time.
This is your opportunity to meet Darren Guillot. As Director of IRS Field Collection Operations, he is in charge of the Revenue Officers you deal with every day. At our last event, Darren shared his views on proper conduct by Revenue Officers and his direct line phone number; proving his dedication to cooperation with the practitioner community.
Darren will describe the IRS’s current budget, staffing issues, and what you can expect in field. He will discuss:
• Priority areas of focus for R.O.s on Collection Cases.
• Employment tax issues and the heightened potential for criminal referral,
• Civil actions,
• Trust Fund Recovery Penalty assertion,
• Suits for injunctive relief, and early interaction and alerts,
• Impersonation concerns, private debt collection initiative, and the enforcement of passport revocation or denial.
11:20 AM - 1:00 PM | Information Please! - 2 Hours
LG Brooks, EA, CTRS
This session is must know information for all tax problem resolution practitioners. When you don’t have information from the IRS, it’s like driving blindfolded. LG will discuss the information IRS must make available to taxpayers and to you as their representative. He will also discuss the information that need not be made available to the taxpayer or to you. For example, requests for information made during the audit can be rejected by the IRS because (they claim) the records constitute investigatory records that are exempt under FOIA. He will explain the requirements for a proper FOIA request and how to present the request to the IRS. LG will also cover the types of transcripts available from the IRS and the information they provide.