Penalty Abatement and Collections: Contesting IRS Assessments
Establishing Reasonable Cause, Filing a Tax Court Petition, Collection Due Process Hearings

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Wednesday, June 25, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
-
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).
-
Live Online
On Demand
This webinar will review penalty abatement laws and procedures and describe the best actions to take in specific circumstances. Our panel of accomplished attorneys will discuss many methods available to abate IRS penalties. They will also describe best practices for building a case that will withstand IRS challenges.
Faculty

Mr. Cole is a senior associate at our law firm. He assists our attorneys with client matters before the Internal Revenue Service (IRS), Franchise Tax Board (FTB), Employment Development Department (EDD), and the State Board of Equalization (SBOE). Prior to joining our firm, Mr. Cole was a Law Clerk at Liberty Mutual Insurance Company. Before joining RJS LAW, he advised clients on various tax, business Law, and estate planning matters. Mr. Cole as also helped hundreds of clients resolve tax problems before the IRS, California Franchise Tax Board, and other tax agencies.

Ms. Diep handles collection cases with the Internal Revenue Service (IRS), Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA), and the Employment Development Department (EDD).

Mr. Engelmann assists with client matters before the Internal Revenue Service (IRS), Franchise Tax Board (FTB), Employment Development Department (EDD), and California Department of Tax and Fee Administration (CDTFA).
Description
Penalty abatement can be a powerful tool in the hands of tax practitioners trying to get the best possible outcome for their clients. Failure to pay and failure to file penalties can total up to 50% of the tax principal owed. This webinar will focus on tax penalties that can be abated for reasonable cause.
This webinar will cover the procedures for applying for penalty abatement. It will then give an overview of the statutes, regulations, and case law governing penalty abatement. Finally, it will cover case building and factual development necessary to create as successful penalty abatement application.
Listen as our panel of federal tax controversy attorneys explains how to navigate IRS penalty abatement and collection procedures to garner the most favorable outcome.
Outline
I. Penalty abatement procedures
A. Written requests
B. Contesting penalty abatement through Tax Court petition
C. Contesting penalty abatement through collection due process hearing
D. Telephone requests
II. Substantive penalty abatement laws
A. Applicable statutes
B. Common grounds for reasonable cause abatement
1. Severe illness or death
2. Reliance on professional advice
3. Financial hardship
4. Recent developments with electronic filing failures
5. Excuses not recognized
III. Case building and factual development
A. Interviewing client
B. Preparing a narrative
C. Gathering exhibits
Benefits
The panel will cover these and other critical issues:
- Contesting penalty abatement by filing a Tax Court petition
- Contesting penalty abatement through a collection due process hearing
- Common grounds for reasonable cause abatement
- Case building and factual development
NASBA Details
Learning Objectives
After completing this course you will be able to:
- Identify acceptable reasonable cause explanations for specific penalties
- Determine when a collection due process hearing can facilitate a resolution
- Decide how to build a case to withstand IRS challenges
- Ascertain when filing a Tax Court petition could be a taxpayer's 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 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.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Unlimited access to premium CLE courses:
- Annual access
- Available live and on-demand
- Best for attorneys and legal professionals
Unlimited access to premium CPE courses.:
- Annual access
- Available live and on-demand
- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
- Available live and on-demand
- Best for legal, accounting, and tax professionals
Unlimited access to Professional Skills and Practice-Ready courses:
- Annual access
- Available on-demand
- Best for new attorneys
Related Courses

Analyzing 1040s for Financial Planning Opportunities
Available On-Demand

Key Revenue Rulings for Trust and Estate Professionals
Wednesday, August 13, 2025
1:00 p.m. ET./10:00 a.m. PT

Trust Distributions to Foreign Beneficiaries: Complex Planning and Calculation Challenges
Wednesday, August 13, 2025
1:00 p.m. ET./10:00 a.m. PT
Recommended Resources
How CPE Can Bridge the Gap Between What You Know and What You Need to Know
- Career Advancement