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Course Details

How to Defend Against IRS Penalties

Webinar: ID# 1015274
Recorded CD
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About This Course:
The Internal Revenue Code has over 140 penalty provisions and the Internal Revenue Service has dramatically increased the number of penalties it imposes on taxpayers.

From 2005 to 2010, the Internal Revenue Service's assessment of accuracy-related penalties against individuals increased by over 800%. Taxpayers who are hit with penalties have different avenues for relief, but often are unaware that relief is available.

This webinar helps taxpayers and tax practitioners understand the different types of penalties that the IRS may assert, how the IRS determines whether to assert penalties, and what taxpayers can do to minimize their risk of being hit with penalties.

The webinar will also give taxpayers and practitioners tools to defend against the assertion of penalties by the IRS, both at the Exam level and at IRS Appeals. Knowing how the IRS views and assesses penalties before the return is even filed is critical to succeeding in defending against penalties if that return is selected for audit.

Agenda

Types of Penalties
  • Accuracy-Related
  • Failure to File/Failure to Pay/Estimated Tax
  • Preparer/Promoter Penalties
  • International Penalties
Contesting Penalties at the Examination or Administrative Level
  • IRS's Approach to Penalties
  • Assessable vs. Nonassessable Penalties
  • Assessment and Abatement Authority Within the Service
Asserting Defenses Against IRS Penalties
  • Reasonable Cause
  • Adequate Disclosure
  • Other Grounds for Abatement of Penalties
The Future of IRS Penalties
About The Presenters

Michelle Abroms Levin
  • Of counsel in the Huntsville office of Sirote & Permutt, PC
  • Practice emphasizes all aspects tax controversy and tax planning; she represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings
  • Prior to joining Sirote, Ms. Levin was a trial attorney at the United States Department of Justice’s Tax Division
  • Ms. Levin speaks regularly on various topics relating to tax controversy, such as navigating international penalties and the IRS audit and appeals process
  • Wrote several publications related to tax controversy and tax planning, including Navigating the Defenses to Valuation Penalties in Charitable Deduction Cases, published in the Journal of Taxation’s December 2014 edition; Ms. Levin’s articles on developments in the world of tax controversy and IRS penalties can be found on Sirote’s tax controversy blog. http://www.sirote.com/blog/tax-controversy/
Ronald A. Levitt, Esq.
  • Shareholder in the Birmingham office of Sirote & Permutt, PC
  • Practice emphasizes all aspects tax, including conservation easements, succession planning, family business planning and tax controversy
  • Conducts regular seminars and workshops on various topics, such as S-corporations, conservation easements and passive-activity rules
  • Wrote several publications related to tax controversy and tax planning, including Navigating the Defenses to Valuation Penalties in Charitable Deduction Cases published in the Journal of Taxation’s December 2014 edition; several articles written by Mr. Levitt can be found in Sirote’s Tax Controversy Blog and Conservation Easement Blog
  • Fellow and member, Board of Regents, American College of Tax Counsel; listed in Best Lawyers in America for more than 20 years in the areas of litigation and controversy-tax, tax law, corporate law, and health care law; named the Best Lawyers’ 2012 Birmingham Tax Law Lawyer of the Year; listed in Alabama Super Lawyers in the areas of tax, closely held business and health care from 2008 - present
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How to Defend Against IRS Penalties
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