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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, March 16, 2023

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$197.00
CPE
ALL

This webinar will address relief provisions available to salvage missed deadlines and elections. Our panel of tax specialists will pair commonly missed tax deadlines and elections with IRS relief that is available to mitigate the related penalties and tax consequences of these oversights.

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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Frank Agostino
President
Agostino & Associates, PC

Mr. Agostino is the founder and president of Agostino & Associates, P.C.  Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. Mr. Agostino also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, he taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. Mr. Agostino also served as the co-director of the Rutgers Federal Tax Law Clinic.

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Description

Tax-specific deadlines are missed for various reasons. Missed tax-specific deadlines can lead to lost legal rights, forfeited tax benefits, hefty penalties, interest, and malpractice claims. Fortunately, statutory, regulatory, and/or administrative relief exists for many missed tax deadlines.

Taxpayers have various options to cure missed deadlines, including but not limited to: section 9100 relief and obtaining a private letter ruling; relief for late-filed tax returns, late-payments of tax, and late-filed claims for credits or refunds; audit reconsideration; equitable tolling; offers in compromise on the ground of doubt as to liability; correcting late-rollovers to qualified retirement plans; and broad relief available in collection due process cases. These strategies can mitigate the otherwise devastating consequences of missed elections, deadlines, and claims.

Listen as our panel of federal tax experts reviews methods available to obtain relief for many commonly missed tax-specific elections, deadlines, and claim selections.

Outline

  1. Introduction
  2. Section 9100 relief
  3. Late-filed tax returns
  4. Late payments of tax
  5. Late-filed claims for credits and refunds
  6. Correcting late rollovers under IRC Section 408(d)(3)
  7. Audit reconsideration
  8. Doubt as to liability offers in compromise
  9. Recent developments concerning equitable tolling
  10. Curing missed elections with private letter rulings
  11. Other relief to cure missed tax deadlines and elections

Benefits

The panel will cover these and other critical issues:

  • Obtaining Section 9100 relief for missed elections
  • Mitigating penalties and interest on account of late-filed tax returns and late payments
  • Fixing missed claims for refund
  • Correcting late rollovers under IRC Code Section 408(d)(3)
  • Developments concerning equitable tolling and the ability of tax authorities and courts to overlook missed deadlines
  • Relief available for late-filed returns and payments
  • When seeking a PLR may be necessary or appropriate

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand the strategies and best practice to “un-miss” deadlines to obtain tax benefits
  • Mitigate penalties and interest for late-filed tax returns, late payments of tax
  • Obtain audit reconsideration when documents in an audit are not timely provided
  • Challenge the underlying tax liability in collection due process cases notwithstanding previously missed deadlines
  • Explain recent developments on the subject of equitable tolling, including when it is available and how to invoke it
  • Ascertain which late elections are covered by Section 9100 relief
  • Appreciate how to qualify for relief for late IRA rollovers
  • Identify when a PLR is necessary or appropriate

  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of individual income taxation, including itemized deductions, individual income tax credits, net operating loss limitations including carrybacks and carryforwards.

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).