IRS Practice Series: The Un-agreed Collection Alternatives and Appeals

Author: Eva Rosenberg

CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

This coursewill prepare you to go through IRS's Fast Track Mediation, prepare your case for the IRS Collections Appeals process, and explain how to prepare a your client's case for the various courts. While you may not be able to represent them in the Court system, you can certainly prove their case and be an expert witness. This course will take you beyond the fundamentals of tax practice and into areas where skill and finesse are required.

Publication Date: June 2016

Designed For
Any proactive, current or prospective, Circular 230 practitioner who understands that the IRS is ramping up the "close the tax gap". Tax practitioners who want to protect their clients from IRS' predatory collections action. 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 develop the skills to prevent and/or resolve IRS collections actions. And tax practitioners who want to grow their business into this rapidly expanding market.

Topics Covered

  • Fast-Track mediation
  • Collections Appeals
  • Collections Appeals Process (CAP)
  • Equivalency hearings
  • Tax Court
  • Court of Appeals
  • Court of Claims
  • District Court
  • Bankruptcy
  • Protective filings to prepare along the way

Learning Objectives

  • Identify tools to get past IRS rejections of Offers in Compromise, Installment Agreements, levy releases
  • Recognize how to expand a tax practitioner's practice base to include representation
  • 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 which court to file an petitions without having to first pay the tax due
  • Describe Fast Track Mediation (FTM)
  • 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
  • Differentiate the guidelines using Collections Appeal Program
  • 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
  • Recognize which court you may not appeal a decision from


Instructional Method

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

Registration Options

Regular Fee$49

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