Are IRS Penalties a Fact of Life? (Completed)
Registration closed on May 16, 2025 at 12:00am Pacific Time
Date: Friday, May 16, 2025
Instructor: Lippes Mathias, Randall P. Andreozzi
| Begin Time: |
9:00am Pacific Time
10:00am Mountain Time
11:00am Central Time
12:00pm Eastern Time |
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
|
NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
IRS has in its arsenal a vast array of penalties for virtually every transgression or misstep imaginable – late filing, late payments, incorrect return positions, foreign financial asset reporting, improper refund claims, to name but a few. And under recent IRS Enforcement Initiatives, IRS Agents impose these penalties aggressively and often as a matter of course. But penalties need not be an oppressive fact of life. This course will explore the penalties available to the IRS and the elements of proof necessary for the IRS to impose them. We will review recent court opinions imposing dramatic limitations on the IRS’ use of penalties, its ability to assess penalties immediately without due process, and the important requirement of managerial approval of penalties. We will provide important practice tips in navigating this legal quagmire to effectively and efficiently defend clients against IRS penalties. Indeed, penalties are not an unavoidable fact of life.
Who Should Attend
CPAs and Enrolled Agents providing tax compliance services for partnerships, corporations and high net worth individuals
Topics Covered
- The vast array of penalties in the IRS’s arsenal
- What the IRS must establish to assert these penalties
- What’s the difference between an assessable penalty and a non-assessable penalty and why id that important?
- The IRS must show managerial approval of a penalty to enforce the penalty
- Practical insights and procedure in challenging penalties
Learning Objectives
- Understand and navigate the elements that the IRS must establish to impose various penalties
- Assist your clients in avoiding IRS penalties
- Assist your clients in effectively and efficiently challenging unwarranted IRS penalties
- Learn and apply new and significant judicial precedent regarding penalties and the IRS’s ability to assess them
- Understand what managerial approval the IRS needs to assert penalties and learn strategies to successfully verify that such approval was secured.
Level
Overview
Instructional Method
Group: Internet-based
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
