Navigating Complex IRS Penalty Abatement Procedures for Failure-to-File, Failure-to-Pay, and Accuracy Related Penalties
Mastering Procedural and Practical Ways to Obtain Penalty Abatement; Mitigating Harsh IRS Penalties
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax professionals with a comprehensive and practical guide to navigating the procedural and practical ways to obtain a penalty abatement. The panel will cover domestic information abatement requests, and will offer useful tools for compiling and submitting the appeal correspondence and documentation.
- Failure-to-file and failure-to-pay penalties (Sec. 6651)
- Know how and when to attach a penalty non-assertion request to a late-filed return
- Learn to effectively establish an installment agreement
- Must learn how to effectively use “Office of Appeals”
- Estimated tax penalty (Sec. 6655)
- Must learn different methods of calculating penalties
- Effectively use the safe harbor rules
- Accuracy-related penalty (Sec. 6662)
- Determining certain tax authority standards (e.g., the “more likely than not” standard or “substantial authority” standard)
- Heavily substantiate a client’s reasonable-cause defense
The panel will discuss these and other important topics:
- Penalty abatement qualifying requirements
- Avoiding notice stream by using a penalty non-assertion request to a late-filed return.
- Establishing an installment agreement and adhering to its terms to avoid penalties
- Effectively using very subjective reasonable cause criteria
- Utilizing “Office of Appeals” effectively
- Methods of calculating penalties
- Which taxpayers can take advantage of the first time abatement program?
Joel N. Crouch
Meadows Collier Reed Cousins Crouch & Ungerman
Mr. Crouch specializes in civil and criminal tax controversies involving sophisticated and... | Read More
Mr. Crouch specializes in civil and criminal tax controversies involving sophisticated and complex legal and tax issues, both domestic and international. He has extensive experience in resolving tax matters at all stages of a tax dispute including IRS examinations, administrative appeals, and litigation in the U.S. Tax Court, the U.S. Court of Federal Claims and U.S. District Courts, and before the United States Supreme Court. He is a frequent speaker on both substantive and procedural tax issues for both legal and accounting professionals.Close
Benjamin J. Peeler, J.D., CPA, LL.M.
Mr. Peeler leads his firm's IRS Practices & Procedures team as a federal tax, controversy and procedure... | Read More
Mr. Peeler leads his firm's IRS Practices & Procedures team as a federal tax, controversy and procedure specialist. He works with clients in the controversy areas relating to income tax, estate and gift tax, property tax, employment tax and other various tax matters. He represents clients before the IRS in examination, appeals, collection, penalty abatement, audit reconsideration, interest abatement and interest netting. Previously, he worked as an attorney for the IRS Office of Chief Counsel, and also, led and instructed groups of attorneys, revenue agents and revenue officers through various procedures.Close
The Law Office of Judi Smith
Ms. Smith is in private practice. Previously, she served as the In-House General Counsel and Director of Strategic... | Read More
Ms. Smith is in private practice. Previously, she served as the In-House General Counsel and Director of Strategic Services for a multinational corporation where she was responsible for domestic and international tax compliance. Prior to leaving, she successfully defended an IRS employment tax (941) audit which concluded with the IRS having no issues. She is authorized to practice before the IRS in all states and territories of the United States. She represents clients with tax issues residing in many countries including Russia, Sweden, India, and China (Hong Kong). She is admitted to practice in the United States Tax Court, the United States Court of Appeals for the Seventh Circuit, the United States District Court for the Northern District of Illinois and the Supreme Court of Illinois.Close