TRSC 2021

For the past 20 years, Miami Attorney Steven Klitzner has devoted his practice to solving the IRS problems of individuals and businesses who owe taxes, are being audited, or who have not filed their returns. The goal in every case is to get the best possible resolution for the taxpayer. To do so, you must develop a relationship and trust with your client and the IRS. Steve will share the tips and tricks he has learned (sometimes through trial and error) to better and efficiently serve his clients and interact with the IRS.

• How to talk to and communicate with prospective and current clients.
• How to talk to and communicate with IRS personnel.
• Decisions you must make to help your clients.
• Easy solutions to complex questions.
• How to handle and resolve your cases faster and more efficiently.

About Steven Klitzner, Esq., CTRS – Steve is the CEO of Florida Tax Solvers. His practice in Miami is 100% focused on IRS Tax Resolution. Steve has presented at many ASTPS conferences in the past and is the newest member of the Boot Camp Training Team. He is admitted to the United States Supreme Court, United States Tax Court, United States Court of Appeals for the Fifth Circuit, and the United States District Court for the Southern District of Florida. He currently sits on the IRS Advisory Council, and is a frequent lecturer on Tax Resolution topics and has presented to thousands of practitioners around the country. He is well known for the humor he brings to his presentations!

Collection Appeals resolves cases involving Collection Due Process, Offer in Compromise, Trust
Fund Recovery Penalties, Jeopardy Levies and Collection Appeals Program (CAP) cases. Shahib will share insights into how practitioners can be more successful when working with appeals.

About Shahid Babar, Director Collection Appeals – Shahid joined the service in 2001 as a revenue officer, and he currently serves as the Director of Collection Appeals. Previously he served as Director, Campus Compliance-Andover in SBSE, Program Manager in Collection Policy overseeing the most significant changes to the Installment Agreement policy and program; Future State project leader for the On-line Payment Agreement (OPA) tool, enhancing and expanding its functionality and usage; Territory Manager in New York City and New England Territories providing leadership and direction for the Compliance and Collection activities. Shahid was an active member of the Collection Enterprise Risk Management team and served as a liaison for the North Atlantic Area. He also served as the Whistleblower Coordinator for the North Atlantic Area Collection monitoring and overseeing whistleblower claims and investigations. Shahid holds a Master of Arts degree in Experimental Psychology with concentration in Research & Methods from City University of NY. He lives in New Hampshire with his wife and three young, beautiful children.

Unpaid payroll taxes are common practice by small business owners. But did you know that the IRS considers unpaid payroll taxes as theft? Employers are required by law to withhold FICA and federal withholdings from an employee’s paycheck, and the government considers those funds as their money. Many small business owners go to prison because of unpaid payroll taxes, not knowing that it was a crime. This program will focus on when and how the IRS considers unpaid payroll taxes as a crime, and what you can do to protect yourself and your client from criminal prosecutions.

After this course you will understand:

• The role of IRS in prosecuting criminal employment tax violations
• The federal statutes that require employers to withhold payroll taxes
• The civil and criminal penalties for failing to withhold or pay over payroll taxes
• The characteristics of when unpaid payroll taxes become a criminal investigation
• How the IRS investigates employment tax crimes
• Real life examples of small business owners going to prison

About former CI Special Agent Robert Nordlander, CPA – Robert has over 20 years of experience with the IRS-Criminal Investigation as a special agent. As a special agent, he has investigated income/employment/excise tax violations, embezzlements, wire fraud, mail fraud, gambling, drug trafficking, bank fraud, money laundering, structuring, and bankruptcy fraud. He has traced assets and income, and has seized millions of dollars in real estate, vehicles, boats, jewelry, financial accounts, and cash.

You’ve probably been there. You have a client in your office with excess baggage. That’s right, they’re in field collection with a Revenue Officer. Now what are you going to do? How are you going to get where you want to be?

This program will provide an overview of field collection, how to effectively work with Revenue Officers, general case processing, and important IRM deadlines. This will include taking a deep dive into the “RO Mindset” along with structuring your casework to flow with IRS case processing actions so you can get to the outcome you want.

By the end of this course you will understand:

• Handling field collection personnel (Revenue Officers and their managers)
• Using the IRM and collection timeframes to leverage resolutions
• Field collection case processing
• Working around the Revenue Officer mentality

About Billy Fauller, III, EA, CTRS – Billy was an IRS Revenue Officer for nearly eight years (Active between 2009 and 2017).  Shortly after leaving he founded Inside Out Tax Resolution Services just outside of St. Louis Missouri. His practice is 100% focused on helping individuals and business owners resolve their tax problems.

Running at a fast pace? Worried about tasks “falling through the cracks?” Always working but not accomplishing as much as you’d want? Are you & your employees best optimizing your working hours How can you do things better, cheaper, and faster?

There are many ways to do things but there’s only one best way. What are the most efficient processes and procedures for your office using less time and resources? This program will focus on what processes are best for your office and how to get more done with less.

After this course you will understand:

• Procedures for employees that help increase efficiency and support auto efficiency
• Tax Resolution Checklists to help control processes and eliminate missed steps
• Structures for Tasks Verticals (tasks groupings) and Client Horizontals that allow for a clear view of outstanding work in progress
• The right level of documentation and standardization for your firm’s size

About Randell Martin, CPA – Randy is a CPA in Dallas, TX and his practice specializes in IRS tax resolution. Randy is certified by the ASTPS as a Certified Tax Resolution Specialist and has been a member of their high level mastermind group for many years. He graduated from the University of Texas at Austin with a degree in Business and a major in Accounting with honors, passed the Texas CPA exam on his first attempt obtaining a Texas license, and graduated with an MBA with high honors from Thunderbird, the American Graduate School of International Management.

Anyone can learn the basics of tax resolution. The difference between good and great representation depends on the representative’s ability to advocate for their client. This course is designed to teach you the power of framing, the basics of persuasive legal writing, and oral advocacy in regards to tax resolution and tax controversy matters. In addition to covering the basics, we will review some tactics and strategies to help you think on your feet. Lastly, we will review a few case studies to show how the power of framing can result in unbelievable outcomes for clients.

• How to frame a legal argument
• Basics of legal writing and oral advocacy
• Mediation and negotiation techniques

About Alyssa Maloof Whatley, JD – Alyssa Maloof Whatley prides herself on honest, aggressive, and compassionate representation of her clients. From the very start of her legal career, Alyssa knew she wanted to help individuals facing financial crisis by focusing on bankruptcy and tax. Alyssa’s firm specializes in IRS representation and bankruptcy out of Atlanta, GA.

The Statutes of Limitations (SOL) are provisions of law that establish an exact or maximum amount of time where either a taxpayer or a government agent is allowed to pursue a legal action or file an administrative claim pertaining to various tax matters, such as, “the right to claim a refund, the right to file suit in court or the authority of the IRS to legally pursue a tax debt”.

The provisions of a SOL are similar to the effects of a “pendulum, whereas the restrictions or provisions of a “statute of limitation” affect and apply to both taxpayers and Government employees alike, thereby preventing “actions” from being initiated by either party. Additionally, the provisions of the statue of limitations may be “invoked” by an action and/or inaction; and the SOL pertaining to tax law matters may be “extended or waived” and possibly even “mitigated” in certain circumstances.

After this course you will understand:

• Identify & understand the provisions of the major “statutes of limitations” with respect to federal tax matter issues
• Adequately analyze, verify & calculate the ASED, CSED & RSED
• Determine whether a particulate “statute of limitation” is in force
• Determine when a SOL may or should be extended, waived, or mitigated
• Be aware of the steps the IRS is required to follow to “protect the statute”
• Understand & know how to effectively utilize the TXMODA transcript to “benchmark” & protect a taxpayer’s recognized statute of limitation
• Understand how “criminal procedures” affect the statute of limitation
• Understand how the issuance of certain “IRS Notices” affect a SOL, as well as other pertinent statue matters

About LG Brooks, EA, CTRS – LG is the Senior Tax Resolution Consultant at Lawler and Witkowski CPA’s. LG has been in the field of taxation for more than 30 years and has been in practice full time since 1990. LG has represented and consulted on thousands of cases and he specializes in resolving high dollar, complex, tax problems all over the country. LG received a Bachelor of Arts degree from Bishop College at Dallas, Texas in 1977.

Often times people automatically assume tax debt is not dischargeable, but the fact is some tax debt is dischargeable and bankruptcy can be a great option for the right type of client. In this course, you will learn the rules for tax dischargeability, basics of Chapter 7 and 13, tax lien treatment in bankruptcy, reading proof of claims, and more.

• How to frame a legal argument
• Basics of legal writing and oral advocacy
• Mediation and negotiation techniques

About Alyssa Maloof Whatley, JD – Alyssa Maloof Whatley prides herself on honest, aggressive, and compassionate representation of her clients. From the very start of her legal career, Alyssa knew she wanted to help individuals facing financial crisis by focusing on bankruptcy and tax. Alyssa’s firm specializes in IRS representation and bankruptcy out of Atlanta, GA.

You are likely familiar with negotiating installment agreements, BUT – Did you know that you can contest the proposed rejection of an installment agreement by requesting a CAP (Collection Appeal Program)?

This program will provide an overview of installment agreements, including negotiating with Revenue Officers, with an emphasis on using the CAP process to prevail on why the IRS should accept your request for an installment agreement. This will include analyzing the Revenue Officer’s narrative (ICS history), reconciling procedures in the IRM, and determining the independent reviewers’ role in making rejection requests.

By the end of this course you will understand:

• Different types of installment agreements
• Negotiating installment agreements in the field
• Requesting and reviewing IRS records
• When to use a CAP and how to use this to your client’s advantage
• Clever strategies to employ when developing a CAP appeal

About Billy Fauller, III, EA, CTRS – Billy was an IRS Revenue Officer for nearly eight years (Active between 2009 and 2017).  Shortly after leaving he founded Inside Out Tax Resolution Services just outside of St. Louis Missouri. His practice is 100% focused on helping individuals and business owners resolve their tax problems.

Collection Standards are used by the IRS to determine ability to pay for Installment Agreements, Currently Not Collectible and Offer in Compromise determinations. The collection standards are also used to limit the clients allowable living expenses. My Practitioners are not fully aware that the IRS Collection Standards are Only Guidelines and that most Collection Standards can be challenged and an amount larger than the National or Local Standard can be allowed by the IRS based on the facts and circumstances and long as it can be demonstrated that they are necessary expenses for the clients or their family’s health, safety and welfare or are necessary for the Production of Income.

• IRS Collection Standards Basics
• What are the Uses of National/Local Standards?
• Why Question National/Local Standards
• When to Challenge National/Local Standard Limits
• How to Justify Larger Necessary Expenses

About David Ramirez, EA, JD, MST, USTCP – David worked for the IRS for nearly 8 years. He has a Bachelor of Science in Business Administration, a Juris Doctor with a Specialization in Taxation, a Masters in Taxation, and a Masters level Certificate in Accountancy. He is a long time member of ASTPS and his tax resolution practice is located in Honolulu , HI.

The IRS is ramping up examinations and onboarding additional IRS examiners after the COVID-19 slowdown. This presentation will outline tips and techniques for handling an IRS examination from inception to conclusion, including options for challenging proposed IRS adjustments post-IRS examination. Specifically, the presentation will include discussion of the following:

• How cases are selected for IRS examination.
• Data that the IRS can access in IRS examination case selection.
• Current IRS examination initiatives and high priority areas for IRS Examination.
• Discussion of due diligence that should be conducted upon receiving notice of an IRS examination.
• Discussion of IRS document requests and responses.
• Strategy for handling issues raised in examinations.
• Considerations related to IRS requests to extend the statute of limitations on assessment.
• Options for challenging proposed IRS examination adjustments.
• Tips for challenging proposed IRS examination adjustments.

About Mary Wood, Esq. – Mary’s practice concentrates on resolving federal and state tax controversies, and white collar crime such as securities, tax and bank fraud. She represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation in the United States Tax Courts, Federal District Courts and United States Court of Federal Claims. Ms. Wood also represents taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies.

As practicing EAs, CPAs and attorneys, you probably are aware of the when liens are put in place against the taxpayer. However, are you aware of what are the steps in perfecting and providing relief from those liens? This program will focus on the various particulars related to these liens.

• Introduction – (i.e., “What is the difference between a lien and a levy?”)
• Lien Acquisition (i.e., Assessment, Notice and Demand, Failure to pay)
• Scoop of a Lien (i.e., Difference between Federal and state determinations, with some court case stories)
• Priority Unperfected Liens (§6323(a))
• Perfection of Liens (the who, what, where, when and how)
• Refiling of FTL’s
• Extending the Lien (Judgements, Transferees, Nominees, Alter Ego)
• Removal of FTL (Withdrawal, Release, Discharges, Subordination, Certificate of Non-attachment)
• Other Provisions (redemption, Civil Damages, Estate tax lien, Insolvency, Bankruptcy)

About Jeffrey Schneider EA, CTRS – Jeffrey is a full time tax resolution professional from Florida. He is a past President of the Florida Society of Enrolled Agents, the Palm Beach Chapter and Treasure Coast Chapter of the Florida Society of Enrolled Agents and a Former Director on the Board of the National Society of Enrolled Agents (NSEA). He is a past recipient of the ASTPS Top Practitioner Award and is a former member of the Internal Revenue Service Advisory Council (IRSAC).