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Strategies for Tax Dispute Resolution (4151507C)
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"CPAs must be prepared for when a revenue agent contacts one of their clients. Attendees of this course will gain a thorough understanding of the civil and potential criminal tax procedure and controversy process involving the IRS and California tax authorities. Additionally, attendees will learn useful techniques and strategies for representing clients in all aspects of tax controversy matters, including tax return examinations, defenses to civil penalties, administrative appeals, tax collecti

12/7/2015
When: 12/7/2015
9:30 AM - 5:30 PM
Where: Webcast/Webinar
Presenter: Steven R Mather, Esq
Contact: April Deneault
801-834-6634


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CPAs must be prepared for when a revenue agent contacts one of their clients. Attendees of this course will gain a thorough understanding of the civil and potential criminal tax procedure and controversy process involving the IRS and California tax authorities.
Additionally, attendees will learn useful techniques and strategies for representing clients in all aspects of tax controversy matters, including tax return examinations, defenses to civil penalties, administrative appeals, tax collection matters and tax fraud cases.
Formerly titled: Tax Procedure and Controversy: Principles and Strategies



  Objectives:




    Identify the structure and operations of IRS and California tax authorities.
    Recognize basic tax procedure principles.
    State common tax procedural issues.
    Outline planning and conducting the tax examination, administrative appeal and collection process.
    Increase your awareness and understanding of ethical considerations.

 
   
  
        
   

Major Subjects:

   



    Examination process: organization of restructured IRS; standards for return selection; examination procedures, including AICPA SSTS (revised); statutes of limitation; the accountant-client privilege; Circular 230 guidelines; IRM application; practical approaches to resolving examination problems, including mediation options.
    Employment tax examination: employee-independent contractor classification issues; Sec. 530 and mitigation rules; trust fund recovery penalty; IRS National Research Program; and IRS Voluntary Classification Settlement Program.
    Civil penalties: accuracy-related penalty; fraud penalty; preparer penalty; promoter and protestor penalties; nondiscretionary penalties; and foreign information return penalty regime.
    Administrative appeals: nature and scope; bypassing appeal; drafting the protest letter; nature, preparation for, and conducting the appeals conference; settlement approaches, including mediation options.
    Collection process: significance of assessment; nature of tax liens and levies; installment agreements; collection due process appeals; offers in compromise; bankruptcy rules; innocent spouse relief.
    Tax fraud: civil tax fraud badges; criminal tax fraud violations; defenses; voluntary disclosures and eggshell examinations; role of Kovel accountant.
    Judicial proceedings: Tax Court; federal district court; Court of Federal Claims; California Superior Court.


    

              

Designed For: CPAs and attorneys who want to more effectively handle tax examinations, appeals, collection and fraud matters with IRS, FTB, EDD and SBE.
 

Prerequisite:  Basic knowledge of dealing with tax authorities preferable.

Advanced Prep:  None

Speaker:  Steven R Mather, Esq

Vendor: CalCPA

Field of Study:     Taxes

Level:  Intermediate

CPE Credit: 8 Hours

Acronym:   TCFS

 

Registration Fees:

Members: $275

Nonmembers: $375

 

Meet the Speaker:

Steve Mather is a partner in Kajan Mather and Barish, practicing in the firm’s Beverly Hills and Orange County offices. Steve handles all manner of civil and criminal tax controversies with the federal and state tax agencies. Steve began his career with the IRS Counsel offices in San Francisco and Los Angeles. Since 1987, he has represented individual and entity taxpayers in a variety of tax disputes. Steve has had dozens of reported decisions in the United States Tax Court and has litigated extensively in the federal district court and in the Ninth Circuit Court of Appeals. Steve is the co-author of the BNA Tax Management Portfolios on federal tax collection, currently entitled “Federal Tax Collection Procedure – Liens, Levies, Suits and Third-Party Liability” and “Federal Tax Collection Procedure – Defensive Measures.” Steve is also the author of the BNA Tax Management Portfolio, “Audit Procedures for Pass-Through Entities.” He received a Bachelor’s Degree in accounting, with highest distinction, and his Juris Doctor, with distinction, from the University of Iowa.

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