These issue & other “Solely to Delay” arguments will be discussed, explored, examined and demonstrated during this presentation.
Alter Ego Issues
One issue of high occurrence lately is the application of the “Alter Ego” doctrine by IRS Collection & Examination personnel.
Tax practitioners should be aware of the current highly litigious environment regarding taxation matters and are further advised to be cognizant of their client’s actions, issues and positions to enable the practitioner to provide relevant & proper advice, and to also enable the practitioner to develop appropriate arguments and raise affirmative defenses pertaining to any tax related engagement. One issue of high occurrence lately is the application of the “Alter Ego” doctrine by IRS Collection & Examination personnel. The classification of your client as an “Alter Ego” of another entity (or person) can have significant adverse legal & financial implications.
The “Alter-Ego” doctrine is not a “newly emerging issue”, however recent activity and implications by Revenue Officers, Revenue Agents and more importantly ATAT Revenue Officers should compel practitioners to address and identify their entity client’s actions, issues & positions with respect to potential “Alter-Ego Reclassification” status.
Speaker: L. G. Brooks, EA, CTRS, NTPI Fellow
Approximately 3 Hours
Audio CDs of recorded live presentation, printed course materials + presentation slides
Continuing Professional Education credits are NOT awarded for recorded self-study seminars.
If, for any reason, you are not satisfied with your purchase, just contact us within 30 days. With the return of all materials in sell-able condition, ASTPS will give you credit toward another seminar of comparable price or will refund your fee. We appreciate that this is an important investment for you and your company and would like to accommodate your needs the best we can.
L. G. Brooks,EA, CTRS, NTPI Fellow
L. G. is the CEO and Senior Consultant of U.S. Tax & Consulting Group. LG is a member of several tax-related organizations and his tax practice includes Tax Representation, Tax Consulting, Tax Preparation and Pre-Tax Court Litigation Support Services. LG received a Bachelor of Arts degree from Bishop College at Dallas, Texas in 1977 and is a Fellow of the National Tax Practice Institute (NTPI) and is currently a faculty member of the National Tax Practice Institute (NTPI) administered by NAEA.
LG has been in the field of taxation for more than 20 years and has been in practice full time since 1990.