Programs

1. The IRS Collection Process: From Billing Notice to Offer-in-Compromise Acceptance Letter: Many practitioners believe IRS collection activities to be random when in fact the process is a very direct and formulaic approach to resolving back tax debts.  This program will explain the process so you can easily understand where your client is in the collection process, and where the opportunities exist to resolve your client’s back-tax issue.  The program includes sample forms and letters so practitioners can see what the various IRS notices look like and recognize them when they show up.

Learning Objectives:

• Understand how the IRS Collection Process works
• Explain the impact of the ten-year collection statute on collection alternatives
• Describe how tax liens work
• Understand the mechanics of a tax levy
• Describe what the four collection alternatives are and when to select one over the other

2. Resolving Back Tax Debts: Offers-in-Compromise, Installment Agreements, Uncollectable Status and Bankruptcy: Taxpayers are in love with the idea of making back-tax debts vanish for pennies on the dollar.  This program will walk practitioners through the various options for resolving a back-tax debt, including case studies and forms to illustrate when each resolution alternative should be considered.

Learning Objectives:

• Identify the collection alternatives with the IRS
• Understand the various types of installment agreements
• Explain the role of tax compliance in resolving a back tax debt

3. Tax Liens & Tax Levies: This program will explain the mechanics of the IRS enforcement tools, when each is utilized and what practitioners can do to assist their client’s either avoid enforced collection or get relief when action is taken. The program will cover how to have tax levies released, discharging and subordinating tax liens, and explain nominee liens and transferee liability.

Learning Objectives:

• Explain the differences between tax liens and tax levies
• Identify when the IRS lien arises
• Explain the options for selling assets out from under a tax lien

4. Making Your Client More Appealing: Utilizing Appeals to Resolve Your Case. Whether by examination or through the collection process, there are times your client will need to seek an independent review of their case to get it resolved.  This program will cover how the Independent office of Appeals operates, how clients can take their cases there to be considered, and how best to line up your client’s case to give them the best opportunity to resolve the tax debt. 

Learning Objectives:

• Understand the various forms of collection appeals
• Explain the role of tax compliance in the appeal
• Identify how cases can get to appeals
• Describe when each type of appeal is appropriate for your taxpayer’s case

5. How to Utilize Collection Appeals: The 1998 IRS Restructuring & Reform Act created numerous new rights for taxpayers.  Among those rights created for taxpayers were appeals of threatened or actual collection action taken.  This program will explain the various forms of appeals – Collection Due Process, Equivalent, CAP – and when and how practitioners can utilize the appeals process to assist taxpayers.

Learning Objectives:

• Understand the various forms of collection appeals
• Explain the role of tax compliance in the appeal
• Describe when each type of appeal is appropriate for your taxpayer’s case

6. Resolving Payroll Tax Issues: The number one reason why small businesses get into tax trouble is due to the failure to report and pay payroll taxes. Payroll tax liabilities are such a large part of the Tax Gap that the IRS has started a number of initiatives to deal with the non-compliance by employers.  This program will cover the current IRS initiatives to deal with payroll tax issues, including the Trust Fund Recovery penalty and how the IRS will pursue responsible owners and employees of the business it believes is responsible for the unpaid payroll taxes.  The program will also review how practitioners can help their client’s either avoid the Trust Fund Recovery Penalty or resolve the personal liability issues.

Learning Objectives

• Understand how the IRS assesses the company and responsible individuals for the unpaid payroll taxes
• Identify who may be deemed personally responsible for the unpaid payroll taxes
• Explain the assessment procedures under IRC § 6672

7. Innocent Spouse Relief from Joint Liability: This program will walk practitioners through the various forms of innocent spouse relief, when each may be used, and how practitioners should go about helping their client to document their case. The program will also review the process for appealing the denial of innocent spouse relief.  Finally, the program will review the differences between Innocent Spouse Relief and Injured Spouse, and when each should be utilized. 

Learning Objectives:

• Identify the types of innocent spouse relief
• Explain the various factors considered by the IRS when deciding to grant relief
• Describe how make the request for innocent spouse relief

8. The Biggest Mistakes Made During Tax Season that Trigger IRS Enforcement! This incredibly popular program will cover those mistakes practitioners make during tax season that can cause the IRS to start enforcement action, either through an audit or collection.  Join us for the program that will help you avoid the pitfalls that can cause you and your client extreme heartburn! 

Learning Objectives:

• Understand the common mistakes made by tax preparers during tax season and how to avoid them
• Identify potential collection issues before there turns are filed
• Understand the strategies for resolving tax debts before they arise

9. The Ultimate Offers-in-Compromise Workshop: Join us as we walk you through how to do an Offer-in-Compromise that gets accepted, including the various forms of Offers, when to utilize each, and how to calculate Reasonable Collection Potential like the IRS. This program includes case studies and a checklist so practitioners can follow-along and learn exactly what to do to become a tax resolution master.

Learning Objectives:

• Identify what different types of Offers exist
• Explain how to select one type of Offer over another
• Describe how the IRS evaluates Offers and Reasonable Collection Potential
• Explain what strategies exist to help your client file an Offer with the greatest chance of success
• Understand what to do when the client defaults on his or her Offer

10. Dealing with an IRS Exam: From Initial Contact to Closing Agreement. This program will walk attendees through the IRS examination process, from opening letter to closing agreement. The program will review the process, opportunities for practitioners to help their taxpayer obtain the best outcome possible, and issues surrounding documentation.

Learning Objectives:

• Explain the audit process
• Identify the issues surrounding client documentation
• Describe the process to challenge an auditors findings

11. Audits of Cash Businesses: When dealing with a cash business the issues surrounding the examination magnify, as now the IRS will delve into what was reported but may have NOT been reported. This program will review what practitioners need to be considering when preparing for an examination of a cash intensive business.

Learning Objectives:

• Identify how the IRS look’s into what was reported or NOT reported
• Recognize what practitioners need to be considering when preparing for an examination of a cash intensive business
• Identify those industries the IRS views as cash intensive
• Understand the various techniques utilized by the IRS to identify unreported income

12. The Schedule C Hobby Loss Exam: We all handle IRS exams, but what do you do when the IRS believes your client’s “business” is not a business at all?  This program will review the Hobby Loss rules under IRC 183 and what practitioners should do before and during the exam to help save those claimed losses.

Learning Objectives:

• Understand the hobby loss rules
• Explain the 9 factors the IRS uses to determine if an activity is a business or hobby
• Identify things the practitioner can do with clients to bolster their case that the activity is not a hobby

13. Handling an IRS Exam When there are Indications of Fraud: What do you do when the routine audit is no longer routine? This program will discuss “eggshell audits”, which are civil IRS exams but where we as the practitioner become aware there is potential tax fraud.  The program will cover potential pitfalls, how to navigate the issues and when to bring the attorneys into the picture.

Learning Objectives:

• Identify things that are indications of fraud to the IRS
• Explain the various privileges tax clients have
• Describe the role accountants can and cannot play in an eggshell audit

14. Criminal Tax for Accountants: This program will review the various tax crimes, and what the government looks for when determining to prosecute a taxpayer or preparer. Emphasis will be placed on reviewing the privileges, including 5^th amendment, attorney-client and accountant-client.  The program also includes a discussion of the accountant’s role in helping the attorneys prepare analysis, recreating records and looking at tax loss calculations for sentencing.

Learning Objectives

• Explain the various types of tax crimes
• Describe the role of the Kovel accountant
• Identify the critical calculation of tax loss

15. The Criminal Tax Investigation Process: This program will explain the criminal tax process to practitioners. The program will cover everything about the criminal tax process, from who the players are in a criminal tax vignette through the investigation and prosecution process.  The program will also cover the role of the Kovel accountant and the critical calculation of tax loss.

Learning Objectives:

• Describe the criminal tax process
• Recognize who the players are in a criminal tax vignette through the investigation and prosecution process
• Explain the various types of tax crimes
• Describe the role of the Kovel accountant
• Identify the critical calculation of tax loss

16. Getting Rid of Tax Penalties: Those late-night commercials make it sound just so easy, but how do you get rid of tax penalties? This program will cover the various penalties applied by the IRS, and the various ways practitioners can seek to have them removed.  The program will cover First Time Penalty Abatement, abatement for reasonable cause, and how to lay the groundwork for avoiding penalties during the audit.

Learning Objectives:

• Understand the first-time abatement program and when it applies
• Describe reasonable cause for avoidance of penalties
• Identify opportunities to avoid penalties during an IRS examination

17. Waking Up the Dead: How to Challenge an Assessed Tax: This program will explain the opportunities for practitioners to reopen assessed tax liabilities, including audit reconsideration, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing. The program will explain each option and when practitioners should consider utilizing each of them.

Learning Objectives:

• Understand how to request audit reconsideration
• Identify when is it possible to use an amended return to reopen a bad assessment
• Explain how Doubt-as-to-Liability Offers work
• Understand how to utilize a CDP hearing to force a reconsideration of a tax liability
• Describe how to use refund requests to reopen a bad assessment

18. Dealing with Non-Filers: The IRS just stated that there are more than 7 million non-filers in the US and are beginning to roll out an initiative to pursue them. The demand for help from practitioners is overwhelming, and very attorneys handle these cases.  The opportunity for CPAs and EAs to help non-filers, resolve the issue, and add a lot money to their bottom line has never been better.  Join Attorney Eric Green as he explains where to find these clients, how to help them, and how to increase your representation practice while doing so..

Learning Objectives:

• Understand the process for bringing non-filers back into the tax season
• Identify opportunities to resolve the client’s outstanding balance
• Explain the strategies for setting up the client to best resolve their federal and state tax issues

19. Responding to an IRS Request for Documentation: Taxpayers get you the numbers, the return goes in, then it all goes away in a blur of tax season and life. That is until 18 months later when the letter arrives for the taxpayer seeking the documentation and other evidence that the numbers on that tax return you prepared for them are valid. Join us for this in-depth program as Tax Attorney Eric Green walks you through the ins-and-outs of documenting your client’s case, what to do when those packages to the IRS seem to vanish into the bureaucratic abyss, and how to handle the situation when your client’s records are less than stellar.

Learning Objectives:

• Understand the examination process for in-person audits and correspondence exams
• Identify potential issues responding to exam notices
• Explain the strategies for handling documentation issues

20. Common Ethical Conundrums in Everyday Tax Practice. We all want to help our clients, but at what point do we begin to cross the line?  This program will review the common ethical issues that arise in a tax practice, and what to watch out for when in the heat of battle (or tax season)!  Topics covered will be the AICPA and Circular 230 rules regarding ethical practice, and common issues like conflict of interest, contingency fee arrangements, the presentation of information to the IRS and amended returns.

Learning Objectives:

• Understand the ethics rules that apply to tax practice
• Identify potential conflicts of interest and how to deal with them
• Explain when a tax practitioner may do work on a contingency fee arrangement

21. Audit Horror Stories: What to Do When the IRS Audit Goes Off the Rails. Join Attorney Eric Green for this fun and informative look at past audit horror stories and the lessons to take away from them, including record storage issues, audit technique goofs and what to do about them.  During the program Eric will discuss how to handle difficult auditors, the client whose dog ate their records, and what can and cannot be done when the auditor does not know how to do their job.

Learning Objectives:

• How to handle a difficult auditor
• Explain how to start reconstructing a client’s records
• Identify issues with audit techniques when they are not applied properly and what to do about it

22. Crazy Tax Cases. Join Eric Green for a fun review of the craziest tax cases, what practitioners and taxpayers can learn from them, and how to apply their lessons to your situation.  Everything from Wesley Snipes protesting to Chesty-Love’s deducting her…um…enhancements, and redefining what “ordinary and necessary” means.  This course walks attendees through the most interesting tax cases and teaches lessons in a fun, unorthodox lecture that is sure to both entertain and educate.

Learning Objectives:

• Identify the arguments tax protestors use to try and explain why they do not need to pay taxes
• Understand the definition of ordinary and necessary expenses for creating income
• Explain the role of perjury and criminal evasion in IRS collection cases, including Offers-in-Compromise

23. How to Bring an IRS Whistleblower Case. When business suffers taxpayers begin cheating. So what can you do if your client knows about tax crimes being committed? They can strike a blow for justice, the American tax system, and get paid doing it. Nothing more American than that!  Attorney Eric Green will review the IRS Whistleblower program, discuss how your client can bring a claim that stands the best chance of receiving an award, and how the system ACTUALLY works!

Learning Objectives:

• Explain how the IRS whistleblower program works
• Describe how whistleblower claims are filed
• Explain how the whistleblower awards are calculated and challenged

24. What To Do When The Auditor is Batshit Crazy. Ever dealt with an auditor that you begin to realize immediately must be named Lucifer?  The point of an audit, according to the IRS itself, is to check on how the taxpayer is doing in respect to their returns and reporting and use this time as an educational opportunity. Yet sometimes there are examiners who do not seem to understand this and have decided it’s a time to torture you and your client.  Trust us, you do not need to take their abuse!  This program will review what to do when the auditor seems to be hell-bent on hurting you, the client, and anyone else who gets in their way.   

Learning Objectives:

• Describe the examination procedures auditors are supposed to follow
• Explain the taxpayer bill of rights
• Identify opportunities to get assistance when the examination process is not working properly

25. The Crazy Stuff Revenue Officers Say, and What To Do When They Say It! Working out a collection alternative with the IRS is not painful.  Well, at least it shouldn’t be. However, every now and then you meet a Revenue Officer who is, shall we say, special?  Some ROs decide to suddenly become auditors, others philosophers, and some just say some really stupid shit.  This program will cover the top stupid things we hear from ROs and what and how you should respond to them.

Learning Objectives

• Describe the IRS collection process
• Explain the issues raised by revenue officers
• Describe options when a revenue officer takes an improper position on a collection issue

26. Walking Annuities: Tax Clients and the Stupid Stuff They Do! It was a hard slog: you dealt with the batshit crazy auditor, then the Revenue Officer who liked to threaten stupid stuff, and finally you worked out the compromise your client wanted and received the acceptance letter.  And then, guess what?  Yup, the client decided to do something on their own and unwound everything!  This program will review actual cases where a client’s stupidity unwound an entire deal, and review how (sometimes) we can salvage the case and save the day. 

Learning Objectives:

• Identify issues clients need to be aware of after their collection case is resolved
• Explain the issues created by social media and what clients must avoid doing
• Describe steps practitioners should consider when dealing with a new representation client

27. Open Your Freaking Mail! And Other Great Advice for Tax Clients.  There is usually a reason why the client is in tax trouble with the IRS.  Guess why?  This program will review the usual mistakes clients make when dealing with the IRS, and what we need to do to educate the client and get them back on the path of compliance and success.   This program will help you close out 2020 with a list of the best advice we have given our Tax Representation clients over the last 20+ years so you have it handy when you need to deal with your clients.

Learning Objectives:

• Understand the IRS exam and collection process
• Identify key steps clients need to take when dealing with the IRS
• Describe opportunities to resolve issues and bring the client’s case to a successful conclusion.

28. How to Onboard the New IRS Representation Client. We love getting new representation clients – they are very lucrative cases.  But what do you do when the phone rings?  How do you get paid? What information should you ask for, and what are your first five steps?  Join us for this special program as Eric Green, the founder of Tax Rep Network, the New England IRS Representation Conference, and his own 22 person tax law firm Green & Sklarz  LLC, walks you through how to onboard these new clients properly to assure you can resolve their issue and make money doing it!

Learning Objectives:

• Determine how to charge for representation services
• Define the first five steps practitioners need to take to start resolving the client’s tax issue
• Identify mistakes most taxpayers make when they start interacting with the IRS

29. How to Complete an IRS Form 433. The way to resolve a taxpayer’s collection case is to understand how the IRS calculates “Reasonable Collection Potential”, or RCP.  The biggest mistake made by practitioners is not understanding how the forms work and how the IRS utilizes its allowable expenses to determine how much the client can afford to pay.

Learning Objectives:

• Explain the uses the IRS has for the Form 433 Collection Information Statement
• Describe the impact of the allowable expenses on the IRS RCP calculation
• Identify issues with the 433 form and explain which version to use for each type of case