Summer Conference

The IRS doesn’t stand still. Procedures shift, enforcement priorities move, and the approach that worked last year quietly stops working. In this field, staying current isn’t a nice-to-have — it’s part of doing right by your clients.

That’s what this day is for.

Five experienced instructors take on the topics that matter most in IRS representation right now. No filler. Each session is built to hand you something you can use the next morning: a sharper case strategy, a tool you didn’t know you had, a way through a problem that’s been quietly costing you time and money.

If you want to stay sharp, get better at the hard cases, and build a more profitable resolution practice, this is the day to clear your calendar for.

Securing the IRS Administrative File

There’s a version of your client’s case the IRS isn’t showing you.

The transcripts you pull tell part of the story. The rest sits in the administrative file — the internal notes, the case history, the procedural steps the IRS may have skipped, the soft spots in its own position. It’s one of the most powerful tools you have. And most practitioners never ask for it.

The ones who do sometimes find the thing that flips the whole case.

This session shows you how to get those records and put them to work. You’ll learn the four ways to pry the file loose — IRS disclosure procedures, administrative file requests, Appeals and collection record requests, and FOIA — and how to get past the disclosure roadblocks that stop most people who try.

What you’ll learn:

• when and how to request the administrative file, and which route fits the matter
• what’s actually in there, and what you can realistically expect to get
• how to navigate the common IRS disclosure challenges
• how to turn internal notes, case history, and procedural gaps into leverage
• how to use what you find to sharpen negotiations and protect your client

You’ll also hear the war stories — real cases where the administrative file changed everything. Missed procedural steps. Hazards buried in the IRS’s position. Favorable internal notes nobody expected. Inconsistencies that cracked a determination wide open.

If you handle complex IRS matters, this is one you can use the next morning.

Presented by LG Brooks, EA, CTRS, and Angelene Wierzbic, EA, CTRS LG Brooks has spent decades solving tax problems most people would walk away from. When the standard record doesn’t tell the whole story, he knows where to dig — and he’ll show you how to find what the IRS would rather you didn’t. He’s joined by Angelene Wierzbic, who’s has spent nearly twenty years on complex resolution cases. Between them, they know these records cold and exactly how to put them to work.

The Unusual Assessments

Most of the time, the IRS has to follow a script before it can assess. Jeopardy, termination, quick and prompt assessments are how it skips the script.

They’re rare enough that plenty of seasoned practitioners have never worked one — and that’s exactly the danger. When one lands on a client, the timelines and protections you normally lean on may not be there. You need to recognize what you’re looking at, fast, because the IRS already has.

These tools are written right into the Code, and the IRS still reaches for them in heightened-compliance situations. This session breaks down what they are, when and why the IRS uses them, who inside the IRS recommends and processes them, and the real damage they can do to a case if you don’t see them coming.

What you’ll learn:

• what jeopardy, termination, quick, and prompt assessments actually are — and how they differ
• the conditions and approval requirements behind each one
• where they come from in the Code and which IRS units, departments, and divisions drive them
• why the IRS still uses them, and the compliance situations that trigger them
• how these assessments can hurt your client — and what it means for how you respond

On paper they look uncommon. In practice, every tax practitioner should know how they work before one shows up in a case.

Presented by LG Brooks, EA, CTRS, and Larry Lawler, CPA, EA, CTRS LG Brooks is the Senior Tax Resolution Consultant at Lawler & Witkowski, CPAs. He’s been in tax for more than 30 years, full time since 1990, and has represented and consulted on thousands of cases — specializing in the high-dollar, complex problems other practitioners get stuck on, all over the country. He’s joined by Larry Lawler, National Director of ASTPS and managing partner of the firm he founded in 1973. A New York CPA since 1973 and a fellow of the NTPI, Larry has represented thousands of taxpayers before the IRS and trains tax professionals nationwide.

Representing Taxpayers with Mental Health, Addiction, and Cognitive Impairments

Sooner or later, you’ll have a client who can’t fully show up for their own case.

Maybe it’s addiction. Maybe it’s a mental health crisis. Maybe it’s a parent slipping into dementia while their tax problem keeps moving. The work doesn’t pause — but your duties shift, and Circular 230 doesn’t hand you a clean script for any of it.

Who are you actually allowed to talk to? What can a power of attorney really do when a client’s capacity is in question? How do you keep the case moving without crossing an ethical line — and protect both your client and yourself while you do it?

This session works through those questions the way they show up in practice: through real case studies, not theory. You’ll leave with a clearer sense of where the lines are and how to handle the moments most CE never prepares you for.

What you’ll learn:

• your ethical obligations and professional boundaries under Circular 230 with vulnerable clients
• how to spot and assess capacity concerns in an IRS matter
• when diminished capacity changes informed consent, decision-making, and the scope of representation
• how to work with family, caregivers, fiduciaries, and legal guardians the right way
• the limits and risks of a power of attorney when a client’s capacity is impaired
• how to document in a way that protects both the client and you
• how to communicate with the IRS about a vulnerable taxpayer
• how to manage client expectations while staying ethically compliant
• real examples of what goes wrong — and what actually works

Presented by Zachary Boutin, CPA, CTRS Zach is an Oregon-licensed CPA and Certified Tax Resolution Specialist, and the Managing Member of First Response Resolution, LLC in Southern Oregon. He represents taxpayers before the IRS and state revenue departments, and his accounting background runs deep — individuals, corporations, partnerships, trusts and estates, even hedge funds. He graduated Summa Cum Laude from Southern Oregon University and brings a steady, practical approach to one of the most delicate situations a practitioner can face.

Representing Clients on the IRS Target List: The Dirty Dozen

By the time these clients reach you, the damage is usually done.

Someone they trusted — a promoter, an advisor, a too-good-to-be-true pitch — talked them into something on the IRS’s Dirty Dozen. A micro-captive. A syndicated conservation easement. A move that looked legitimate right up until the audit notice landed.

Now it’s your case. So what can you actually do for them?

This session walks through how to represent clients who fell for one of these schemes: how to prepare them for the audits that follow, what defenses may be available to people who were genuinely victims of bad advice, and how to work these cases without getting pulled under with them. You’ll get practical, in-the-weeds guidance from someone who’s seen the Dirty Dozen from both sides of the table.

What you’ll learn:

• the bad advice clients are getting from promoters of Dirty Dozen schemes — and how to spot it
• how to prepare a client for an audit tied to one of these items
• what defenses may be available to taxpayers who were victims of a scheme
• practical strategy for working cases involving items the IRS has flagged

Presented by Samantha L. Gozlan, Esq. Samantha is a Senior Associate at Lippes Mathias, where she focuses on tax controversy and audit defense — federal income tax and gratuitous transfer tax matters, including cases before the U.S. Tax Court. Before that, she worked inside the IRS Office of Chief Counsel in the Large Business and International division, on large partnership and Global High Wealth examinations, micro-captive and syndicated conservation easement compliance, and BBA partnership audits. In other words, she knows how the IRS approaches these cases — because she worked them from the inside.

The American Society of Tax Problem Solvers is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.NASBARegistry.org.

The American Society of Tax Problem Solvers (ASTPS) is an approved continuing education provider through the IRS.