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How To Defend Against IRS Penalties

Resource Material: ID# 1007755
About This Course:
The Internal Revenue Code has more than 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 more than 800%. Taxpayers who are hit with penalties have different avenues for relief, but often are unaware that relief is available. This topic 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.

Taxpayers and practitioners are also given 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.

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' Approach to Penalties
  • Assessable vs. Non-Assessable 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 Your Speaker:

    Michelle Abroms Levin
    • Of counsel with Sirote & Permutt, PC and a member of the firm’s Tax Controversy Practice Group
    • Represents clients during all phases of federal tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, and federal district court
    • Prior to joining Sirote, she was a trial attorney at the United States Department of Justice’s Tax Division
    • Speaks regularly on various topics relating to tax controversy, such as navigating international penalties and the IRS audit and appeals process
    • J.D. degree, University of Texas School of Law; B.S.B.A. degree, magna cum laude, Washington University, Olin School of Business
    Gregory P. Rhodes
    • Shareholder in the Birmingham office of Sirote & Permutt, PC
    • Practice emphasizes tax controversies, tax litigation and tax planning
    • 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; Mr. Rhodes’ 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/
    • J.D. degree, University of Mississippi; LL.M. degree in taxation, New York University
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    How To Defend Against IRS Penalties
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