Tax collection issues can be as simple as responding to a bill or as complicated as a bankruptcy reorganization. To represent a client in a tax collection matter, a CPA should have a fundamental understanding of tax collection laws and practices. It is critical to understand the available options for resolving tax collection cases and the procedures available for reaching those resolutions. This course will analyze applicable laws, procedures and potential resolutions, including the law of tax liens and levies and procedures available for resolving a tax collection matter. We will cover alternative resolutions, including installment agreements, offers in compromise and bankruptcy in detail. The virtues of the collection due process procedures will be discussed in detail.
Assessment and attachment rules-tax assessment procedures and attachment of the assessment lien to property, including community property. Tax liens-perfection and priority rules in general and for specific assets and relief from liens. Tax levies and seizures-taxpayer rights and defenses, third party rights. Dealing with the collection officers and representatives. Collection appeals-collection due process (CDP) and other collection appeals. Collection resolutions-offers in compromise, installment agreements, bankruptcy. Judicial actions: collection due process (CDP), injunctions, and IRS suits.
Working knowledge of resolving tax bills helpful or professionals who handle tax collection issues with the IRS, FTB, EDD and CDTFA.
CPAs, attorneys, enrolled agents.
Recognize the tax collection functions of the IRS tax authorities. Understand the law of tax liens and levies, including attachment to property, perfection and priority over competing interests. Identify the available procedures, including collection due process (CDP), other collection appeals and lien relief alternatives. Determine and compare the options for resolving collection issues, including installment agreement and offer in compromise rules and discharging and resolving taxes in bankruptcy.
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