IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Tuesday, May 26, 2020
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This course will provide tax advisers with insights on handling IRS audits from inception to resolution, including responding to IDRs (information document requests), extending the statute, working with newly titled Independent Office of Appeals, and litigating unresolved issues. The panel will review areas the IRS is targeting, how to cooperate without oversharing, and steps to take to lessen the chance of selection.
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). Mr. Stigile frequently writes and lectures on topics involving taxation.
All tax practitioners need to be up-to-date on the latest IRS tax initiatives and current IRS audit procedures. Before the audit takes place, advisers need to understand the different types of examinations, the current IRS audit process, and when returns are no longer subject to audit. The type of audit: correspondence, office, field or compliance affects the effort and ease of resolving the issue(s) raised.
Since most audits take place just before the statute runs, deciding whether to grant the IRS an extension of time is often a critical initial consideration. Throughout the process, there is a fine line between cooperating with the IRS and its voluminous information document requests (IDRs) and providing information that could be damaging.
Most practitioners are aware of the benefits of appeal after receiving a disagreeable Revenue Agent's Report. Here, a case may settle for less than the full amount assessed. The recently enacted Taxpayer First Act of 2019 ensures all taxpayers with legitimate claims have access to the IRS independent appeals process.
Certain taxpayers, those with AGI of $400,000 or less or business taxpayers with gross receipts of $5 million or less, can request access to their file before going to court. Filing an effective written protest can circumvent going to court, saving the taxpayer significant time and money. Then again, there are times when a 90-day letter and trip to tax court may be the best or only alternative.
Listen as our panel of experts explains the IRS examination process, how to handle appeals when court is a viable alternative, and steps taxpayers can take to circumvent or ease the audit process.
- Types of IRS examinations
- Audit selection process
- Current IRS initiatives
- Responding: IDRs and correspondence
- Extending the statute
- Appeals
- Litigation
- Criminal investigations
The panel will review these and other important issues:
- The effect of the Taxpayer First Act on the IRS audit process
- How to respond to disagreeable Revenue Agent Reports
- Current areas IRS is targeting for examinations
- Considerations when responding to IDRs
- Negotiating with the Independent Office of Appeals
Learning Objectives
After completing this course, you will be able to:
- Identify types of IRS examinations
- Decide when a return may be audited
- Ascertain when going to appeals may be beneficial to the taxpayer
- Determine when litigation may be the best alternative
- 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 pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.
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.
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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