Penalty Abatement and Collections: Contesting IRS Assessments

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.

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

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

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.

IRS Approved Provider

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