CPAs must be prepared when the IRS or California tax agencies contact one of their clients. Learn useful techniques and strategies for representing clients in all aspects of tax controversy matters. Topics discussed include amending and disclosing errors, defenses to civil penalties, tax return examinations, tax fraud cases, administrative appeals, tax collection matters and tax litigation. Particular emphasis will be placed on using procedural rights to achieve better results in difficult cases. We will cover the procedures but focus on how to use them to obtain better results for the client.
Examination process: organization of IRS, standards for return selection, AICPA SSTS (revised), Circular 230 guidelines, amended returns, and approaches to resolving examination problems. Civil penalties: delinquency penalties, accuracy-related penalty, fraud penalty, preparer penalty, promoter and protestor penalties, and foreign information return penalty regime. Audits and administrative appeals: nature and scope, docketed v. nondocketed appeals, appeals conferences, and settlement approaches. Collection process: significance of assessment, nature of tax liens and levies, installment agreements, collection due process, offers in compromise and bankruptcy. Tax fraud: civil tax fraud badges, criminal tax fraud violations, defenses, voluntary disclosures, and the role of Kovel. Judicial proceedings: Tax Court process, federal district court. Court of Federal Claims.
Basic knowledge of dealing with tax authorities.
CPAs, attorneys and tax preparers.
Identify the structure and operations of IRS tax authorities. Recognize basic strategies for handling audits, appeals and collection cases. Determine how to use procedural rights to achieve better results. Outline planning and conducting the tax examination, administrative appeal and collection process.
STEVEN R. MATHER, ESQ. Steve Mather is a partner in Kajan Mather and Barish, practicing in the firm’s Beverly Hills and Orange County offices. Steve handles all manner of civil and criminal tax controversies with the federal and state tax agencies. Steve began his career with the IRS Counsel offices in San Francisco and Los Angeles. Since 1987, he has represented individual and entity taxpayers in a variety of tax disputes. Steve has had dozens of reported decisions in the United States Tax Court and has litigated extensively in the federal district court and in the Ninth Circuit Court of Appeals. Steve is the co-author of the BNA Tax Management Portfolios on federal tax collection, currently entitled “Federal Tax Collection Procedure – Liens, Levies, Suits and Third-Party Liability” and “Federal Tax Collection Procedure – Defensive Measures.” Steve is also the author of the BNA Tax Management Portfolio, “Audit Procedures for Pass-Through Entities.” He received a Bachelor’s Degree in accounting, with highest distinction, and his Juris Doctor, with distinction, from the University of Iowa.
Non-Member Price $399.00
Member Price $299.00