Highlights
• 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 the role of Kovel accountant
• Judicial proceedings: Tax Court process, federal district court, Court of Federal Claims and California Superior Court
Objectives
• Identify strategies for handling audits, appeals and collection cases
• Recognize difficult or sensitive issues and how to defend them
• Determine how to use procedural rights to achieve better results