| One of the most powerful tools a taxpayer representative has is the right to elevate a case to the Independent Office of Appeals. This right has been strengthened under the 2019 Taxpayer First Act. Now, when a case comes before Appeals, they will look at it “de novo” or with “fresh eyes.” They will not be influenced by the IRS personnel involved in the case any more than they will be influenced by the taxpayer. They will review the case, apply the law, review reasonable arguments, and render an independent finding.
Using one of the new rights afforded by the Taxpayer First Act, representatives can be fully prepared by securing the entire case file prior to any hearing. This allows the representative to be prepared for the arguments put forth by the Exam or Collection Divisions.
Sooner or later every practitioner will encounter a situation that can be best resolved In the Appeals Division. Attending this special session will help you to be prepared when that situation arises. The types of Appeals covered will include: Audit decisions, Collection Due Process (CDP), Equivalent Hearing (EH), Collection Appeals Program (CAP), Trust Fund Recovery Penalty (TFRP), and Offer in Compromise (OIC).
This course will cover the following topics as they relate to the Appeals Process:
- Handling Small Case Requests
- Preparation and Filing of Formal Protests
- Enforcement Actions Leading to Appeals
- Statute of Limitations on Appeals
- Consideration of the Taxpayer Bill of Rights
- Trust Fund Recovery Penalty
As a Special Feature a case study will be included regarding the complex requirements of a Formal Written Protest. After completing this course, you will be able to:
- File A Winning Appeal after an Audit
- Effectively Appeal Collection Due Process Notices
- Appeal Denial of Installment Agreements
- Appeal Penalties
Participants will earn 2.0 CPE/CE credits
Field of Study: Taxation
Price: $97 Non-member / $92.15 Standard / $82.45 Premium
Course presented by: Jo-Ann Weiner, EA, CFE, CTRS
Jo-Ann has over 35 years of experience with the IRS as a Revenue Agent auditing federal tax returns and working as a special enforcement agent on civil cases, criminal cases, and grand jury cases. She has served as an expert witness testifying in court for the government. Jo-Ann worked for the IRS as an outside contractor teaching Corporate Taxation to IRS Revenue Agents. |