Responding to Adverse IRS Audit Assessments: Audit Reconsideration Requests, IRS Appeals, Settlement Strategies
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and professionals with a discussion of IRS exam hotspots. It will outline practical strategies for responding to unfavorable IRS audit results, including requesting audit reconsiderations, navigating the IRS appeals process, and the litigation options available. The participants will learn how to adequately represent and negotiate with the IRS during the audit and through the reconsideration and appeal process.
- Responses to initial IRS examination contact
- Responding to IDRs, and requests for taxpayer interviews
- Statute of limitations issues during the audit process
- IRS appeals process: strategies and requirements
- Offers in compromise based upon doubt as to liability
- Audit reconsideration requests
- Contesting notices of deficiency: litigation alternatives
- Collection due process hearings
The panel will discuss these and other vital questions:
- How to respond to Information Document Request Form 4564
- How to respond to IRS requests for taxpayer interviews
- Strategies and requirements for audit reconsideration
- Under what circumstances should a representative advise the taxpayer to extend the statute of limitations?
- When is the IRS appeals process beneficial for taxpayers?
- What belongs in an appeals protest?
- When should a representative advise filing a petition with the U.S. Tax Court?
Dennis N. Brager, Esq.
Certified Tax Specialist
Brager Tax Law Group
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and... | Read More
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and tax controversy matters. Before founding the Brager Tax Law Group, a Los Angeles-based tax litigation and tax controversy law firm, he was a senior trial attorney for the Internal Revenue Service’s Office of Chief Counsel. Since 2008 he has represented several hundred clients with offshore accounts. He also represents clients on a variety of issues, including criminal and civil tax fraud, tax audit and appeals, payroll and sales tax problems, tax preparer penalties, innocent spouse defenses, offers in compromise, installment payment agreements, Office of Professional Responsibility (“OPR”) defenses and more.Close
Cheryl R. Frank
Brager Tax Law Group
Ms. Frank is a former Senior Tax Attorney in the Tax Litigation Division of the IRS Office of Chief Counsel in... | Read More
Ms. Frank is a former Senior Tax Attorney in the Tax Litigation Division of the IRS Office of Chief Counsel in Washington DC. Her area of expertise was Tax Shelter Litigation, which included partnerships and tax accounting issues. In addition to representing the IRS in Court, Ms. Frank advised the IRS on complex issues relating to tax accounting and partnership taxation. She was a founding member of the Tax Shelter Injunction Task Force Committee at the Department of Justice. For the last 36 years Ms. Frank has limited her practice to representing clients who have disputes with the IRS as well as other State taxing authorities.Close