IRS Practice Series: The Un-agreed Collection Alternatives and Appeals (Currently Unavailable)

Author: Eva Rosenberg

Get a clear review of the IRS Fast Track Mediation Program, as well as strategies for preparing your case during the Collections Appeal process. You'll learn more about how to support clients when you're unable to personally represent them to help resolve audits successfully. Learn the changes in procedure due to COVID19 and the IRS shutdowns.

Publication Date: June 2021

Designed For
Any proactive, current or prospective, Circular 230 practitioner (CPA, EA, attorney or tax preparer) who understands that the IRS is ramping up the "close the tax gap". Tax practitioners who want to prevent the erosion of their client base, as their clients turn to free and cheap tax preparation services online. Tax practitioners who want to protect their clients from IRS' predatory collections action, develop the skills to prevent and/or resolve IRS collections actions and grow their business into this rapidly expanding market.

Topics Covered

• Early Referral and Fast Track Mediation
• Collections Appeals
  • Collection Due Process
  • Collection Appeal Process Equivalency Hearing
  • Post Appeals Mediation (PAM)
• Tax Court
• Court of Appeals, Court of Claims, District Court

Learning Objectives

• Identify tools to get past IRS rejections of Offers in Compromise, Installment Agreements, levy releases
• Identify which form to use to submit an Offer in Compromise (OIC)
• Recognize who handles Fast Track Mediation (FTM) and which situations qualify
• Differentiate the three types of Offer in Compromise
• Identify the steps to take through the Collections Appeals Process (CAP)
• Describe when to initiate a CDP hearing
• Recognize in which court to file a petition without having to first pay the tax due
• Describe various IRS mediation options
• Identify what to do if a penalty abatement request is denied
• Evaluate why you shouldn't withdraw a Collections Due Process (CDP) request and the reasons to do so
• Describe the differences between a CDP and an Equivalency Hearing
• Recognize the Tax Court rights of Enrolled Agents and CPAs
• Identify why a tax practitioner should include their signed Power of Attorney form when helping a client file a pro se case in Tax Court
• Identify when to file a suit for refund in District Court or the Court of Claims for a taxpayer who has paid the tax
• Identify a correct statement regarding the Appeals System
• Identify which form should be used to request Fast Track Settlements
• Recognize what is eligible for Fast Track Mediation or Fast Track Settlement
• Describe what Internal Revenue Code §6511(h)(2) provides

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
IRS Practice Series: Overview of Collection Issues and IRS Practice Series: 10 Steps to Resolving Collection Issues (or equivalent knowledge).

Advance Preparation
None.