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One day to advance your tax resolution knowledge!
The IRS is constantly evolving and changing. It’s up to practitioners like you to stay up to date on the latest best practices to best serve your clients.
Our Advanced Conference Series exists for one reason – to help you increase your tax resolution confidence and capabilities. We want to help make you as efficient, effective, and profitable as possible!
The Spring Conference is your chance to hear presentations on hot topics and receive critical updates that effect your IRS representation business. The one day event will be jam packed with a total of 5 presentations taught by 5 different instructors. Set aside just one day to gain skills and knowledge to help you better represent your clients before the IRS.
5 ALL NEW PRESENTATIONS!
Raising & Establishing “The Burden of Proof”
Presented by LG Brooks, EA, CTRS (2 Hours)
Various courts from numerous circuits have stated or recognized that “the term burden of proof is one of the slipperiest members of the family of legal terms”. The Supreme Court also weighed in on this matter by explaining that “the confusion arises, in part, from the fact that “burden of proof” (BOP) historically encompassed the “burden of production” as well as the burden of persuasion”. These two sub-elements, together, comprise the “burden of proof”.
Tax practitioners & tax representatives, should be aware of the basis of the “burden of proof” as it usually pertains to all levels of tax law (Examination, Collection & Appeals), and should be “raised & established” at the earliest stage of a tax controversy or tax engagement to provide the element of credibility with respect to the tax issues or tax matters subject to investigation or interrogation by the Internal Revenue Service (IRS).
By the end of this course you will understand:
- Identifying & understanding the Internal Revenue Code definition of BOP
- Explaining the legal components of the BOP
- Demonstrating how to “raise & establish” the BOP during a tax engagement
- Explaining how to challenge the IRS with the BOP regarding a fraud matter
- Use of the BOP to defend the taxpayer concerning an employment tax matter
- Exploring how a FOIA request could assist in the application of a BOP defense
- Understanding the weight of and critical development of a BOP argument
About LG – 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.
Statute of Limitations: Friend or Foe? It Depends.
Presented by Larry Lawler, CPA, EA, CTRS (1 Hour)
The intricacies of the Statute of Limitations (SOL) in tax matters can be both fascinating and formidable. Join us for an insightful session where we explore the delicate balance between taxpayer rights and regulatory constraints.
Scenario: The Unreported Income Dilemma
Imagine this scenario: An auditor uncovers unreported income during an audit for the tax year 2021. The taxpayer insists that the income was already accounted for in the 2020 tax return. The auditor proposes amending the 2020 return, but there’s a catch—the Refund Statute of Limitations (RSED) has lapsed. Consequently, the taxpayer faces potential double taxation on the adjusted income.
Mitigation Provisions: A Ray of Hope
Fear not! The mitigation provisions may offer relief. In this seminar, we’ll delve into scenarios where these provisions can be a lifeline for taxpayers dealing with adjustments spanning both open and closed tax years. However, it’s essential to recognize that mitigation isn’t always a panacea; it can also work against taxpayers.
Exploring Judicial Remedies: Recoupment, Set Off, and Estoppel
We’ll venture beyond the statutory realm to explore judicial remedies. Recoupment, set off, and estoppel—these legal tools play a crucial role in resolving tax disputes. We’ll compare the essential differences to the mitigation provisions defined under IRC §1311 – §1314.
About Larry – Larry is the National Director of ASTPS and has represented literally thousands of taxpayers before the Internal Revenue Service and is a frequent public speaker, a writer on professional topics, and a regular trainer of tax professionals nationwide. He has become nationally recognized for his skills in solving tax problems, and has been a New York Certified Public Accountant since 1973. He is also a fellow of the NTPI and the managing partner of Lawler & Witkowski, CPAs, PC, the firm he established in 1973.
Demystifying the FBAR
Presented by Michael J. DeBlis III, Esq
Learn the purpose of the FBAR regulations Determine who must file the FBAR Determine the FBAR filing requirements Determine who is exempt from the FBAR filing requirements Understand the civil and criminal penalties that may be applicable for not complying with the FBAR filing requirements
By the end of this course you will understand:
- Deconstructing the FBAR rule
- Most Commonly Asked Questions About the FBAR
- IRS Procedures for Ensuring Consistency and Effectiveness in Administering Civil FBAR Penalties
- The Elusiveness of Willfulness
- Beyond the FBAR – Everything You Never Wanted to Know About All of the Other International Reporting Forms but Must
- Challenging the IRS’s Assertion of the Non-willful FBAR Penalty: A New Hope
About Michael – Michael is a partner in the boutique law firm of DeBlis Law where he specializes in tax compliance and entertainment law. Michael graduated from Western Michigan University School of Law in 2007 and later went on to earn his Masters of Law in taxation (LL.M.) from Thomas Jefferson School of Law in 2012.
CAP Appeals – The Overlooked And Forgotten Tool
Presented by Steve Klitzner, ESQ., CTRS (1 Hour)
Tax Practitioners often utilize the Collection Due Process Appeal to resolve their cases. However, there are times when the CDP is not available. That is when the CAP Appeal may be the best answer. Often overlooked and forgotten, CAPs have their own rules and timelines. Miami Tax Attorney Steven Klitzner will take you step by step through the process. Steve will show you how to use the CAP Appeal for levy releases, proposed levies, liens, and rejection, termination, and modification of installment agreements.
By the end of this course you will understand:
- How and when to file a CAP Appeal
- The procedures and rules for CAP Appeals
- How to win a CAP Appeal for levy releases, proposed levies, liens, and rejection, termination, and modification of installment agreements
About Steve – 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 Accelerator 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.
Deep Dive into ICS and Supporting IRS Software
Presented by Billy Fauller, III, EA, CTRS (1 Hours)
Embark on an expertly guided journey through the intricacies of Integrated Collection System (ICS) and its supporting IRS software. This comprehensive course is meticulously designed for professionals aiming to master the operational framework and coded language that form the backbone of tax collection.
By the end of this course you will understand:
- Deep Dive into ICS and Supporting IRS Softwares
- Learn what different codes and transactions in ICS mean.
- Know how to follow the chronology in a case as told through the electronic record.
- Understand different case actions taken and why these are significant.
- Learn how to identify systemic case entries from IAT and ATFR.
- Obtain insider insights into IDRS, the infrastructure for the whole tax system!
About Billy – 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.
– New Feature –
1 Hour Q&A with all 5 Speakers
Larry Lawler, LG Brooks, Ang Wierzbic, Steve Klitzner, and Billy Fauller
We will end our jam packed day of training with a one hour question and answer session. Any questions that didn’t get answered during the individual sessions will get addressed during the Q&A. Attendees will also be able to ask new questions to the speakers.
Event Details:
Thursday, May 9th
10:00 – 11:00 | Mitigation Provisions under 1312
11:00 – 11:10 | Break
11:10 – 1:00 | The Burden of Proof
1:00 – 2:00 | Lunch
2:00 – 3:00 | Demystifying the FBAR
3:00 – 3:10 | Break
3:10 – 4:10 | Deep Dive into ICS and Supporting IRS Software
4:10 – 4:20 | Break
4:20 – 5:20 | CAP appeals
5:20 – 5:30 | Break
5:30 – 6:30 | All Speakers Q&A Session
ALL TIMES IN EASTERN
Webinar Platform: Zoom
Continuing Education: 7 Hours of CE/CPE
Handout Material: Delivered Virtually
Event Recording: Yes, 12 Month Access
Membership Discounts: Discounts apply to the member and their staff/w2 employees only. Registration under the wrong membership type will result in the registration being refunded and you will lose your spot and need to reregister.
Multiple Registrations: If registering 3 or more members of the same firm please contact ASTPS for additional discounts.
Cancellation Policy: Full refund 30 days prior to the event. 50% Refund 30-14 days prior. 14 days or less will receive a full credit.
This Events Features:
COMPLETELY VIRTUAL
7 HOURS OF CE/CPE
12 MONTH ACCESS TO RECORDINGS
More knowledge = more profit
It’s simple – The more you know and understand about tax resolution, the quicker and more efficiently you can work cases. This should result in more profit per case!
Confidently Represent
What was once difficult eventually becomes routine. As you gain confidence in your tax resolution abilities you can command higher fees and increase your capacity to take on work. More clients means more revenue.
Learn from Real Experts
If you’ve decided to commit a major part of your career to tax resolution you don’t have to reinvent the wheel. By attending a program like the Spring Conference you are going to learn best practices from seasoned professionals.
Member Discounts Apply
Membership discounts apply to this program. 15% for Premium members and 5% for Standard members.