Description
Course Description
Gain a better understanding of how to substantially reduce IRS tax penalties.
There are dozens of different penalties the IRS can assert against taxpayers. The defenses to such penalties are just as varied and often ill-defined in current guidance. Practitioners are often unaware of exactly how and when to challenge various IRS penalties. This topic will help tax practitioners understand the mechanics of various penalties and how best to defend taxpayers against IRS penalties. The material explains what defenses are applicable to certain penalties, how and when to assert such defenses, and methods for negotiating a reduction in penalties at various procedural stages. IRS penalty reduction/abatement has been decreasing steadily for the past decade – practitioners must therefore execute defenses to IRS penalties with precision to be successful. This material is critical for practitioners who represent taxpayers at all stages of tax controversy, from the initial examination stages all the way through final adjudication.
Learning Objectives
– You will be able to describe the difference between substantial authority and reasonable basis for tax positions.
– You will be able to discuss the different methods of challenging the assertion of IRS penalties.
– You will be able to identify various types of IRS penalties.
– You will be able to recognize reasonable cause and other defenses to IRS penalties.
Presenter: Logan Chaney Abernathy, Dentons Sirote
Credits*: AIPB, CLE, Enrolled Agents, CPE
Time of program 90 min, 1 pm ET
Date of program September 23, 2024
