CPAs must be prepared when the IRS or California tax agencies contact one of their clients. Learn useful techniques and strategies for representing clients in all aspects of tax controversy matters. Topics discussed include amending and disclosing errors, defenses to civil penalties, tax return examinations, tax fraud cases, administrative appeals, tax collection matters and tax litigation. Particular emphasis will be placed on using procedural rights to achieve better results in difficult cases. We will cover the procedures but focus on how to use them to obtain better results for the client.
Learning Objectives
- Identify strategies for handling audits, appeals and collection cases
- Recognize difficult or sensitive issues and how to defend them
- Determine how to use procedural rights to achieve better results
Major Topics
- Examination process: organization of IRS, standards for return selection; AICPA SSTS (revised), Circular 230 guidelines, amended returns and approaches to resolving examination problems
- Civil penalties, delinquency penalties, accuracy-related penalty, fraud penalty, preparer penalty, promoter and protestor penalties and foreign information return penalty regime
- Audits and administrative appeals, nature and scope; docketed v. nondocketed appeals, appeals conferences and settlement approaches
- Collection process: significance of assessment; nature of tax liens and levies, installment agreements, collection due process, offers in compromise and bankruptcy
- Tax fraud: civil tax fraud badges, criminal tax fraud violations, defenses, voluntary disclosures the role of Kovel accountant
- Judicial proceedings: Tax Court process, federal district court, Court of Federal Claims and California Superior Court
