Navigating the IRS Appeals Office Process: Achieving Settlement, Avoiding Litigation
Filing Formal Protests, Appealing Collection Actions, Requesting Collections Due Process Hearings Through Appeals
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and professionals with an advanced guide to navigating the IRS appeals processes. The panel will go beyond the basics to offer an in-depth guide to leveraging the appeals process to challenge not only assessments, but also collections proceedings. The webinar will include specific examples of navigating each stage of the appeals process.
- Structure of IRS Appeals Office
- Settlement authority vested in Appeals Officers
- “Litigation hazards” consideration
- Appeal Officers’ authority to reopen previously closed cases and assessments
- Process of filing an appeal
- Tactics and strategies for pursuing a claim through the Appeals Office
- Collection appeals and requesting a collection due process hearing or appeal
- Illustrations and examples
The panel will discuss these and other critical topics:
- What challenges may a taxpayer bring to the Appeals Office?
- How does the requirement that an Appeals Officer consider the “hazards of litigation” serve as an advantage to taxpayers and advisers in bringing an appeal?
- When should a taxpayer docket a case before going through the appeals process?
- Using the appeals process to challenge collection actions or address tax assessments that have not yet been challenged
- How do the policy and procedure changes announced in October 2016 impact taxpayers and advisers pursuing formal appeals?
Mary I. Slonina
Ms. Slonina is Director on the Tax Controversy and Regulatory Services team within Washington National Tax... | Read More
Ms. Slonina is Director on the Tax Controversy and Regulatory Services team within Washington National Tax Services. She provides guidance and assistance to clients in regards to IRS practice and procedure, including representing clients in administrative interactions with the IRS (Examination, Collection, Office of Appeals, and Chief Counsel). Her areas of concentration include entity classification, FIRPTA transactions, IRS collection actions, penalty abatement relief, statute of limitations, 2014 Offshore Voluntary Disclosure Program (and related disclosure initiatives), and private letter ruling requests (including Treas. Reg. 301.9100 relief).Close
Ms. Askey is a principal in Pwc’s Tax Controversy and Regulatory Services (TCRS) practice. To this role, she... | Read More
Ms. Askey is a principal in Pwc’s Tax Controversy and Regulatory Services (TCRS) practice. To this role, she brings more than 20 years of experience in assisting multinational corporations with the prevention and resolution of complex tax controversies. She has represented her clients before the IRS, in litigation, and in policy matters (both regulatory and legislative) before the US Department of the Treasury and the Congressional tax-writing committees. Previously, she held senior positions at Ernst & Young LLP and Pillsbury Winthrop Shaw Pittman LLP. She also formerly served at the US Treasury Department’s Office of Tax Policy, first as an Attorney-Advisor in the Office of Tax Legislative Counsel, and then as Associate Tax Legislative Counsel.Close