IRS Representation, Audits and Penalty Abetment Updates

Adam Fayne

Adam Fayne

Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white-collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money...
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Pre-recorded
180 Mins
Adam Fayne

Session 1 - 2022 IRS Representation Updates

The Internal Revenue Service changes and announces new initiatives every year. This webinar by tax attorney Adam Fayne will discuss the current enforcement and audit initiatives of the Internal Revenue Service and how these efforts may continue during 2022. During the webinar, Adam will also discuss the Internal Revenue Service’s latest 2022 initiatives and how you can prepare for a successful year in representing your clients. There is also a high probability that the Internal Revenue Service will have its first material budget increase in more than a decade. Adam will discuss how this increased budget will impact your clients. For example, will the Internal Revenue Service audit more taxpayers, will the Internal Revenue Service become more efficient in taxpayer communication, and how will collection activity increase. You can be assured that with an increased budget the Internal Revenue Service will be knocking on more doors for those missing tax dollars.

Session Objectives

The objective of this session is to provide insight and tools to assist you and your clients understand what the Internal Revenue Service will focus on during 2022 and how successful they were during 2021. During the session, Adam will discuss what a large budget increase to the Internal Revenue Service will mean for taxpayers.

Session Highlights

  • IRS Audit Activity during 2021
  • IRS Collection Activity during 2021
  • IRS priorities for 2022
  • IRS Budget and what it means for your client
  • New Programs that may be beneficial to your client


Session 2 - IRS Audits and Appeals

This webinar will provide an update of current IRS exam and settlement initiatives and procedures. Taxpayers have increasingly needed to seek the assistance of the IRS Appeals Division due to their inability to obtain a satisfactory result at the examination stage. Taxpayers who are audited usually have a right to appeal any determination by an examination agent. Taxpayers also enjoy the right to appeal certain IRS collection enforcement actions, including seizures and liens

Session Objectives

This webinar will provide insight and tools to assist your client to navigate audits that are both routine and may have a criminal or fraud element.  You will learn how to respond to Information Document Requests, how to engage the auditor, how to navigate the delicate balance was fraud is involved, and how to exercise your rights to appeal an unsatisfactory audit determination to the IRS Office of Appeals or the US Tax Court.

Session Highlights

  • How to prepare for an audit and respond to Information Document Requests.
  • How to navigate an audit when fraud is involved.
  • How to respond to a Summons request.
  • Available options when you disagree with an audit determination – Appeals, Tax Court, and District Court
  • Settlement initiatives of the IRS


Session 3 - Penalty Abatement Requests and Litigation

The IRS asserts millions of dollars in tax penalties against taxpayers each year. This webinar session will teach you how to represent your client and seek abatement and removal of IRS penalties. You will learn about Reasonable Cause exceptions to penalties, various methods to request penalty abatement, and how to litigate penalty abatement requests when you are unsuccessful in the examination or appellate stage. We will also discuss the various types of penalties that the IRS may assert against your client.

Session Objectives

  • This program will provide insight and tools to assist you and your clients understand what penalties may be asserted if certain actions are taken, or not taken
  • You will learn how to dispute penalties at the various stages of a penalty lifecycle, e.g., examination stage, appellate stage, collection stage, and refund stage
  • Lastly, you will learn about the ability to dispute penalties administratively and through formal litigation in Tax Court and District Court.

Session Highlights

  • The various penalties the IRS could assert against a taxpayer, including penalties related to foreign assets.
  • Contesting Penalties in Examination
  • Contesting Penalties in Appeals
  • Contesting Penalties in Tax Court
  • Contesting Penalties in District Court
  • Automatic vs Discretionary Penalties
  • Reasonable Cause exception to Penalties

 

Note: This is a combo of 3 Webinars (60-minute each)

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