A tax compliance practice begins with a study of a client's business and tax needs and circumstances, which lead to tax planning and return preparation. Then, as is happening more often, the IRS exam. While the audit conclusion is the endpoint for many practitioners, a competent tax adviser should know about the subsequent steps in the controversy process and be prepared to represent a client past the unagreed examination.
It is at this juncture in the compliance process where costs (tax, penalties, interest and representation) become the major concern of the client.
Expand your controversy and representation knowledge and skills, which can serve to facilitate your menu of service offerings and expand your tool kit.
While this course is presented at the intermediate level, less experienced practice participants should have no problem assimilating the material toward the above ends.
Recognize why Appeals exists.
Identify Appeals processes that can be used when disputes arise.
Choose the best route to pursue when a case is unagreed at Examination or Appeals.
Recall how to perform required actions: Filing the protest, interacting with the Appeals Officer, settling based on hazards analyses and taking the next step at Appeals.
Recognize Appeal penalties and identify how to negotiate penalty settlements.
Identify how to use closing agreements.
Determine alternative dispute resolution techniques at Examination and Appeals.
Appeals mission, background and history
Whether to go to Appeals, pros and cons of Appeals and what to expect
Appeals independence, ways to settle a case, burden of proof and the protest
Appeals conference; closing the case with or without resolution; settlement practice and procedure
Hazards of litigation
Penalty disposition, closing agreements and alternative dispute resolution
Practitioners who represent taxpayers before the Office of Appeals; who desire to represent or assist an appeals specialist with their own or another's clients in the appeals process; or who want to learn enough about the process to effectively advise their own clients about the next step(s) in the administrative appeals process.
Prerequisite: Broad and substantial knowledge of our federal tax system, including compliance; an understanding of the IRS tax examination process; and tax representation methodology and rules. Less experienced practitioners can benefit, as well, as the class is presented in a organized, descriptive and explanatory manner.
Advanced Prep: None
Speaker: Jack E. Tucker
Field of Study: Taxes
CPE Credit: 8 Hours
Meet the Speaker:
Jack Tucker is a federal tax appeals and dispute resolution consultant, an educator, and a mediator. He's based in Thousand Oaks, California. He has business degree (ANDERSON/UCLA), finance/accounting degree (MBA/CSULB), and his MBA in taxation (Golden Gate). He worked for a Fortune "100" company as a senior cost accountant; he later became an IRS Revenue Agent (San Francisco); then a Quality Reviewer (with LA Examination District Technical Coordinator, Large Case, and Appeals). He taught (Lead Instructor) and was a text writer (Washington D.C.). Several years later Jack took the tax manager position for a large CPA firm and eventually began his own "niche" accounting firm while continuing to teach accounting and tax courses at the college and graduate levels. More recently he sold the firm to focus on consulting, providing written materials and teaching CPE in the above mentioned subject areas.