Before this course, the concept of navigating IRS penalties and the Reasonable Cause criteria may seem overwhelming to many tax professionals. This course acts as a bridge, providing clear and concise guidance on the IRS Penalty Abatement Program. It delves into the utilization of the Internal Revenue Manual, IRC, Regulations, and case law to support clients' reasonable cause arguments. The course offers a thorough understanding of the First Time Abatement Program, teaching attendees when and how to leverage it effectively. It also updates on Revenue Procedure 84-35 in the context of the new Partnership Audit Regime. Participants will learn to analyze reasonable cause issues, craft effective abatement and appeal letters, and correctly use Form 843. After completing this course, professionals will be well-prepared to assist their clients in reducing IRS penalties, turning a challenging situation into a manageable one with informed strategies and solutions.
Learning Objectives
Upon completion of this course, participants will be able to:
Describe the glossary of terms to Know
Explain and depict Reasonable Cause Assistant {RCA}
Interpret First Time Abatement {FTA} Program and distinguish when to use and when not to
Explain Revenue Procedure 84-35 and will offer an update if still available since the new Partnership Audit Regime
Analyze, Discuss and translate Reasonable Cause issues for penalty abatement
Illustrate and present Abatement and or Appeal Letter Formats
Educate and discuss Form 843 and when to use
Enlighten on the procedure for filing and usage on Form 8275
Major Topics
Reasonable Cause and Good Faith
Case Law
Revenue Procedure 84-35, 194-1 C.B. 509