• videocam Live Webinar with Live Q&A
  • calendar_month September 24, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process

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$347.00
$294.95
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Discount expires 9/10/26

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CLE
CPE
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About the Course

Introduction

This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign information reporting forms, their associated penalties, and FBAR abatement requests. The panel will offer useful tools for compiling and submitting the appeal correspondence and documentation.

Description

The IRS employs strict standards for determining whether a taxpayer qualifies for penalty abatement for failure to file required foreign information returns and FBARs.

IRS audits have not become more manageable. Once chosen, a taxpayer can expect to face a probing investigation, potentially leading to stiff penalties. Critical to navigating the FBAR and foreign information reporting forms appeals process is understanding the legal standards, the potential penalty level, arguments (legal and otherwise), and evidence to assemble. Counsel and advisers must prepare to present a comprehensive and cohesive case for taxpayers seeking to appeal their FBAR and other penalties.

Listen as our experienced panel of advisers provides a practical guide to navigating the process for handling penalty abatement denials. Attendees will receive an insider's look at how leading practitioners resolve complicated international controversies.

Presented By

Zaher Fallahi, CPA
Tax Attorney
Zaher Fallahi

Mr. Fallahi represents individuals and businesses in complex U.S. and international tax matters before the IRS, FinCEN, OFAC and the US Department of the Treasury. 

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Daniel N. Price
Attorney
Law Offices of Daniel N.Price, PLLC

Mr. Price's legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Mr. Price served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Mr. Price has had unique experience with tax controversy and tax administration.  ​

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Credit Information

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

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

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


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, September 24, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Not just the FBAR: a review of the foreign reporting forms

II. The administrative remedy paths: proactive and reactive

III. The review standards: willfulness and reasonable cause

The panel will review these and other key issues:

  • Recognize approaches to resolve international controversies
  • Identify the types of lesser-known foreign asset transactions that trigger significant penalty risks
  • Determine legal and practical issues that can erupt in these cases and approaches to mitigate those risks
  • Discuss the relevant law applied during audit and appeal

Learning Objectives

After completing this course, you will be able to:

  • Ascertain approaches to resolve international controversies
  • Identify the types of lesser-known foreign asset transactions that trigger significant penalty risks
  • Recognize relevant law applied during audit and appeal
  • 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+ law or accounting firm experience at mid-level within the organization, interpreting or preparing complex tax forms and schedules for domestic and multinational businesses; supervisory authority over other attorneys/tax staff. Knowledge and understanding of foreign information filing requirements and penalties for non-compliance; familiarity with IRS processes for penalty abatement requests and appeals of IRS penalties.

BARBRI, 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

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

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .