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Penalty Abatement and Collections: Contesting IRS Assessments

Establishing Reasonable Cause, Filing a Tax Court Petition, Collection Due Process Hearings

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Wednesday, June 25, 2025

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, June 13, 2025

or call 1-800-926-7926
Add to your calendar

This webinar will review penalty abatement laws and procedures and describe the best actions to take in specific circumstances. Our panel of accomplished attorneys will discuss many methods available to abate IRS penalties. They will also describe best practices for building a case that will withstand IRS challenges.

Description

Penalty abatement can be a powerful tool in the hands of tax practitioners trying to get the best possible outcome for their clients. Failure to pay and failure to file penalties can total up to 50% of the tax principal owed. This webinar will focus on tax penalties that can be abated for reasonable cause.

This webinar will cover the procedures for applying for penalty abatement. It will then give an overview of the statutes, regulations, and case law governing penalty abatement. Finally, it will cover case building and factual development necessary to create as successful penalty abatement application.

Listen as our panel of federal tax controversy attorneys explains how to navigate IRS penalty abatement and collection procedures to garner the most favorable outcome.

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Outline

  1. Penalty abatement procedures
    1. Written requests
    2. Contesting penalty abatement through Tax Court petition
    3. Contesting penalty abatement through collection due process hearing
    4. Telephone requests
  2. Substantive penalty abatement laws
    1. Applicable statutes
    2. Common grounds for reasonable cause abatement
      1. Severe illness or death
      2. Reliance on professional advice
      3. Financial hardship
      4. Recent developments with electronic filing failures
      5. Excuses not recognized
  3. Case building and factual development
    1. Interviewing client
    2. Preparing a narrative
    3. Gathering exhibits

Benefits

The panel will cover these and other critical issues:

  • Contesting penalty abatement by filing a Tax Court petition
  • Contesting penalty abatement through a collection due process hearing
  • Common grounds for reasonable cause abatement
  • Case building and factual development

Faculty

Cole, Joseph
Joseph Cole, Esq., LL.M.
Senior Associate Attorney
RJS LAW Firm

Mr. Cole assists with client matters before the Internal Revenue Service (IRS), Franchise Tax Board (FTB), Employment...  |  Read More

Diep, Chandara
Chandara Diep, Esq., LL.M.
Managing Partner
RJS LAW Firm

Ms. Diep handles collection cases with the Internal Revenue Service (IRS), Franchise Tax Board...  |  Read More

Engelmann, Christopher
Christopher Engelmann, Esq., LL.M.
Attorney
RJS LAW Firm

Mr. Engelmann assists with client matters before the Internal Revenue Service (IRS), Franchise Tax Board (FTB),...  |  Read More

Attend on June 25

Early Discount (through 06/13/25)

CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.

Cannot Attend June 25?

Early Discount (through 06/13/25)

CPE credit is not available on downloads.

CPE On-Demand

See NASBA details.