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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, March 18, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE webinar will provide tax counsel and advisers guidance on the best practices to resolve federal tax controversies. The panelists also discuss the impact of recent tax cases, navigating administrative appeals procedures, and recent IRS enforcement initiatives. The panelists will also discuss key considerations in resolving tax controversies and offer practical tips in light of recent court cases, potential changes under the new administration, pitfalls to avoid, and other vital items.

Faculty

Lawrence A. Sannicandro
Partner
Pillsbury Winthrop Shaw Pittman LLP

Mr. Sannicandro focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses (both public and private). These disputes cover the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas,  criminal tax investigations and prosecutions, litigation before the United States Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts and state tax tribunals. Mr. Sannicandro has favorably resolved hundreds of tax disputes involving income taxes, estate and gift taxes, employment and payroll taxes, excise taxes, sales and use taxes, federal and state tax credits, and employee plan matters. Drawing on his background as a former estate and gift tax attorney for the IRS, he is uniquely well-versed in estate and gift tax planning techniques, the valuation of closely held businesses, and defending those planning and valuation techniques in disputes with tax authorities. Mr. Sannicandro also works with clients to provide substantive legal advice on uncertain tax positions, identify and quantify tax-based risks, and proactively manage those risks through various procedural strategies.

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Jeffrey M. Glassman
Partner
Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP

Mr. Glassman is a firm partner with a practice focus that includes counseling individuals, businesses, and trusts and estates with respect to their most demanding tax planning and controversy issues. His tax controversy practice involves representing clients in all stages of civil and criminal tax matters, including complex IRS examinations, administrative appeals, ruling requests, payroll tax disputes, federal tax collection issues, government investigations, and litigation. Mr. Glassman works with clients in developing strategies to resolve sensitive compliance issues such as unreported income and undeclared offshore accounts and assets. He also advises individuals regarding emerging technology tax issues related to cryptocurrencies, non-fungible tokens, and other digital assets. Recently, Mr. Glassman has focused significant time on tax disputes involving private aircraft and employee retention credit matters (ERC), including ERC refund lawsuits against the federal government.  The vast majority of his cases are resolved privately and never made public.

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Description

The IRS has been aggressively enforcing compliance with U.S. tax rules and regulations, which has caused many practitioners to be involved for the first time with administrative appeals and tax-related litigation. Moreover, the IRS has involved counsel and attempted to identify abusive transactions earlier in the process, which requires practitioners to be more thoughtful in resolving matters with the IRS. Tax counsel and advisers must understand applicable tax rules, administrative procedures, taxpayer rights, and other key items in order to effectively represent taxpayer-clients.

Recent tax cases provide insight into the IRS' enforcement priorities and the types of issues giving rise to disputes with taxpayers that are difficult to resolve in an audit, on appeals, or other means.

Possessing an in-depth understanding of procedural tax rules and regulations will assist counsel and tax advisers in helping taxpayers maintain compliance, manage audit risk, and avoid costly and time-consuming audits and investigations.

Listen as our panel discusses tax litigation, administrative proceedings, and appeals processes in detail as well as key areas of focus for counsel and advisers.

Outline

  1. Overview of the tax controversy process
  2. Best practices to resolve tax controversies involving the IRS
  3. Compliance and resolution options, including the various programs to voluntarily come into compliance
  4. The current enforcement landscape, including as a result of clawbacks of funding under the Inflation Reduction Act of 2022 and executive orders to reduce the federal workforce
  5. Current developments, including recent tax cases and administrative developments affecting controversies involving the IRS

Benefits

The panel will discuss these and other key issues:

  • Navigating the administrative and judicial tax controversy process
  • What are the critical challenges of tax controversies, administrative appeals, the district court, and tax court?
  • What compliance and resolution options are available prior to and during tax proceedings?
  • Navigating potential penalties and designing defense strategies
  • What is the impact of recent court cases on tax audits, examinations, administrative appeals, investigations, and litigation?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify income tax compliance issues and pitfalls to avoid
  • Understand penalty structures for non-willful and willful failure to file
  • Acquire defense strategies and available tools to consider when facing tax litigation
  • Identify critical challenges of tax controversies, administrative appeals, the district court, and tax court litigation

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules for domestic and multinational businesses; supervisory authority over other preparers/accountants. Knowledge and understanding of information filing requirements and penalties for non-compliance; familiarity with IRS processes for penalty abatement requests and civil fraud cases.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).