The 4180-interview used in Trust Fund Liability investigations is one of the tools the IRS has in its toolbox. This session will teach participants how to protect their clients rights and mount a TFRP Defense.

This discussion will highlight issues that come up in the three areas of tax practice, audit, collection, and criminal enforcement. It will touch on malpractice pitfalls and protecting the client as well as possible areas of exposure to the practitioner. Gary will highlight key notices to watch out for and there implications both in audit and collection. He’ll also address strategies in these two areas as well as touch on criminal issues that impact both audit and collection representation.

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.

This seminar provides several recommendations to prevent engaging that one client that you wish you had never agreed to represent. Larry will help you avoid that one bad client engagement decision that offsets all the benefits of ten good cases.

Taxpayer representatives generally approach representation with the intent of doing everything possible to reduce taxes, eliminate penalties, and generally protect their clients from unwarranted IRS actions.

Taxpayer & tax case related interviews have always been a major point of concern with respect to interactions with Internal Revenue Service (IRS) investigations and audits. However, recent developments and actions attempted to be implemented by the IRS specifically pertaining to “taxpayer interviews” should heighten the concern of all practitioners representing taxpayers before the IRS. This webinar presentation is designed to discuss & expose the recent “improper, inappropriate & illegal” actions that may be employed on a national level.

In this program you will cover all of the IRS Appeals Mediation Programs where you get the opportunity to look the IRS in the eye and present your position. A mediator will oversee the conference and assist both parties to come together and resolve the case. Steve will take you through the entire process from start to finish and lay out everything you need to know about Fast Track Settlement, Early Referral, Fast Track Mediation, and Post Appeals Mediation, so that you will be fully prepared to get the best deal for your client.

Most tax practitioners don’t know about Appeals Mediation. Most IRS employees have very little experience with it. Yet, it is an important tool that you can use to resolve difficult IRS collection and examination cases. Miami Tax Attorney Steven Klitzner will take you step by step through the Mediation process and show you how to use it to your advantage to get better deals for your clients. Steve will also tell you the details of a recent Mediation he successfully concluded.

One of the most effective strategies the IRS has to get a taxpayer’s attention is the bank levy. Losing access to their money is often an incredibly upsetting and stressful situation and they will turn to you, their tax professional, for guidance. After this short presentation you will know the basic procedures to relieve their distress and release the bank levy.

This class will cover reviewing IRS Transcripts to determine which tax debts are dischargeable and when. This class will cover the basics of Beard and McCoy cases and how they are used in the calculations. The class is a must for anyone wanting to partner with Bankruptcy Attorneys for referrals or Attorneys who want to learn the mechanics of the calculations.

Taxpayer representatives need to know how and when taxes may be discharged in bankruptcy. You might be surprised to know that many bankruptcy lawyers don’t even know the rules! This presentation teaches you how to advise your clients, and their attorneys, as to when taxes may be eliminated through bankruptcy.
This presentation will be taught by Larry Heinkel, a Florida tax attorney who has been practicing bankruptcy and tax law for more than 34 years.

The Examination Compliance Function of the IRS is operating and functioning at a heightened level, with special emphasis towards Schedule C filers. Additionally the audit/examination process has changed and is constantly evolving and unfortunately redirects the focus towards practitioners. This presentation will attempt to prepare you for the new procedures and the new audit/exam personnel you may encounter.

The audit/examination process has changed and is constantly evolving and unfortunately redirects the focus towards practitioners. This presentation will attempt to prepare you for the new procedures and the new audit/exam personnel you may encounter to ensure that we not make the “mistakes” that are not so apparent during an examination.

Subsequent to an “un-agreed” or non-productive IRS audit or examination, taxpayers may be entitled to file a formal appeal (if the ASED permits) and/or pursue other viable options. Nonetheless, excluding a formal appeal, another option does exist which is available to taxpayers concerning this tax matter. As a result of these options, taxpayers may decide to do nothing and allow the tax deficiency to be assessed, file a formal appeal or better yet, taxpayers may decide to pursue another “second chance” option, known as the “Audit Reconsideration” process.

We will learn strategies for representing and advising a client during an audit when there is a risk of a civil fraud penalty, or worse, a referral to the Department of Justice for criminal prosecution. Learn about the tools the Internal Revenue Service uses to identify fraud, criminal behavior, and the tools in your chest to try and mitigate the damage.

Are you seeing more clients with CP2000 letters? Wondering how to make these cases more profitable and less time-consuming? Do you understand how to win these cases from the start and how to set expectations correctly with clients? Do you want to learn how you can manage CP2000s cheaper, faster, and better?

One of FINCENs primary goals is regulating and enforcing the Bank Secrecy Act (BSA), which is a law that requires businesses and financial institutions to provide documentation to regulators whenever their clients deal with suspicious cash transactions involving sums over $10,000. In this webinar we will cover the basics of the Bank Secrecy Act, reporting requirements, sample scenarios, and more.

By the end of this course you will understand the IRS audit selection process. You will know exactly how you can detect your clients IRS Exams months in advance. Finally you will learn how to mitigate the results using amended returns to reduce/remove penalties, first time penalty abatements, and other best practices.

Most examinations of personal tax returns involving Schedule C self-employment request information on car and truck expenses. Although the code mandates a written mileage log, the IRS is aware that most taxpayers do not maintain one. In this quick one hour presentation we will discuss how to properly recreate these mileage logs if you happen to have a client under audit.

This webinar will provide practical guidance for representing individual taxpayers during an IRS examination, including audit basics, pitfalls to avoid, privilege considerations, how to challenge audit determinations, and detecting/avoiding possible involvement by the IRS Criminal Investigation Division (CID). Mark C. Milton started his career as a Trial Attorney with the U.S. Department of Justice, Tax Division, in Washington, DC.

This webinar will discuss the types of IRS audits and the process to appeal an auditor’s findings. We will discuss the four appeals options and what an appeals officer will, and will not do once your case is assigned. Will discuss the role of appeals if your case is docketed for tax court. Will also discuss how you can appeal IRS’ collection enforcement action such as liens and levies and how you can take IRS’s collection action to court. We will also discuss ways to resolves outstanding tax debt including trust fund recovery penalties

There are hidden compliance issues which can prevent processing that we should be aware of as practitioners. Things like unassessed Trust Fund Taxes can deem your OIC unprocessable. Don’t fall into the IRS trap and get your perfect OIC bounced.

Of the three types of offers in compromise, doubt as to collectibility (DATC) is by far the most common. This presentation addresses the essential elements of the DATC offer. Your speaker, National Director Larry Lawler, CPA, EA, CTRS will cover acceptance criteria, income and allowable expenses, equity in assets, dissipation of assets, reasonable collection potential, non-liable persons, streamline offers, and the important terms of the OIC contract. He will also discuss IRS rejection of an OIC in favor of an installment agreement, and finally he will be sure to add some of the insights and tips you’ve come to expect from his presentations

The attendees during this presentation will learn the basics of completing the Collection Information Statement, Form 433 and:
• What are National and Local Standards
• How to Apply the information received
• Compute Reasonable Collection Potential
• A case study with information presented by the clients
• Potential ideas to lower the amount including potential hardship
• What may or may not be accepted
• How to prepare he 656

In this webinar, we will discuss ethical issues that might arise when both spouses are your clients. Specifically, we will talk about how to identify and address the potential conflicts of interest when representing spouses in tax return preparation, a civil audit, or tax collection matter. Participants will also learn to recognize when a client has a viable claim for innocent spouse relief, as well as the impact of joint and several liability on tax collection matters, and how to address these issues with clients.

This 2 hour presentation will cover what is an innocent spouse. A brief discussion on injured spouse including the effects of being in a community property state. Finally we will cover applicable Internal Revenue Codes and walk through examples from court cases.

Your client can’t do an Offer in Compromise. They can’t pay what they owe without the Statute of Limitations on Collections expiring. They cannot get the IRS to put him in CNC status. Now what? A PPIA may be your best alternative, but do you know how to get that done? Based on several recent consulting calls it seems there is a lot of confusion about the simple process.

In some cases, the IRS even tries to get the taxpayer’s delinquent returns filed by preparing returns on behalf of the taxpayer. There are also some non-filers who purposely do not file as a means to fraudulently hide income. As practitioners, we need to know who we are dealing with, and how to handle these scenarios.

Filing the non-filer is an overview on how to file tax returns for taxpayers who have not filed for a number of years. We will be discussing the common problems that perpetuate an individual from not filing a tax return, and how to creatively overcome these unique problems.

In this course, you’ll learn how to represent clients who don’t file their tax returns. You’ll learn how to resolve IRS issues related to non-filing. Upon completion of this course, you’ll be able to: Explain why some taxpayers stop filing tax returns, Calculate how long it takes to bring a taxpayer back into compliance, Analyze best practices for representing non-filing clients, Recognize IRS investigation techniques, Identify who might be prosecuted for non-filing, and more!

In this course, you’ll learn how to represent clients who don’t file their tax returns. You’ll learn how to resolve IRS issues related to non-filing. Upon completion of this course, you’ll be able to: Explain why some taxpayers stop filing tax returns, Calculate how long it takes to bring a taxpayer back into compliance, Analyze best practices for representing non-filing clients, Recognize IRS investigation techniques, Identify who might be prosecuted for non-filing, and more!