Penalty Abatement Requests and Litigation: 2023 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
60 Mins
Adam Fayne

Review of various penalties, IRS could assert against a taxpayer, including penalties related to foreign assets!

The IRS asserts millions of dollars in tax penalties against taxpayers each year. This webinar will cover how to represent your client and seek abatement and removal of IRS penalties. You will learn about Reasonable Cause exceptions to penalties, the First Time Penalty Abatement procedures, various methods to request penalty abatement (e.g. in exam, appeals, post-appeals, Collection Due Process), and how to litigate penalty abatement requests when you are unsuccessful in the examination, administrative, or appellate stage. Our expert speaker, Adam Fayne will also discuss the various types of penalties that the IRS may assert against your client.

Webinar Objectives


This webinar 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.

Webinar 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 Collection Due Process
  • Contesting Penalties in Tax Court
  • Contesting Penalties in District Court
  • Automatic vs Discretionary Penalties
  • Reasonable Cause exception to Penalties

Who Should Attend


  • Accountants
  • Tax preparers
  • CFOs
  • Financial Compliance Professionals
  • Lawyers
Event Registration
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$199.00
$199.00
$299.00
$299.00
$199.00
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