Remedying Missed Elections, Deadlines, and Claims: Section 9100 Relief and Other Strategies to Fix Missed Elections, Deadlines, and Claims
Recording of a 110-minute CPE webinar with Q&A
This webinar will address relief provisions available to salvage missed deadlines and elections. Our panel of tax specialists will pair commonly missed tax deadlines and elections with IRS relief that is available to mitigate the related penalties and tax consequences of these oversights.
Outline
- Introduction
- Section 9100 relief
- Late-filed tax returns
- Late payments of tax
- Late-filed claims for credits and refunds
- Correcting late rollovers under IRC Section 408(d)(3)
- Audit reconsideration
- Doubt as to liability offers in compromise
- Recent developments concerning equitable tolling
- Curing missed elections with private letter rulings
- Other relief to cure missed tax deadlines and elections
Benefits
The panel will cover these and other critical issues:
- Obtaining Section 9100 relief for missed elections
- Mitigating penalties and interest on account of late-filed tax returns and late payments
- Fixing missed claims for refund
- Correcting late rollovers under IRC Code Section 408(d)(3)
- Developments concerning equitable tolling and the ability of tax authorities and courts to overlook missed deadlines
- Relief available for late-filed returns and payments
- When seeking a PLR may be necessary or appropriate
Faculty
Frank Agostino
President
Agostino & Associates
Mr. Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice,... | Read More
Mr. Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. Mr. Agostino also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, he taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. Mr. Agostino also served as the co-director of the Rutgers Federal Tax Law Clinic.
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Lawrence A. Sannicandro
Partner
McCarter & English
Mr. Sannicandro focuses his practice on federal and state tax controversies, including representation in audits,... | Read More
Mr. Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.
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