IRS enforcement priorities are shifting rapidly as legislative mandates, new judicial decisions, and evolving global tax risks reshape the landscape for 2026. This course provides a forward‑looking, practice‑focused overview of the trends shaping IRS campaigns, audit strategies, penalty enforcement, and high‑visibility initiatives targeting large partnerships, high‑net‑worth individuals, international transactions, and emerging areas such as cryptocurrency, foreign accounts, and cannabis-related businesses. Participants will gain practical insights into navigating coordinated LB&I and SBSE audits, responding to IRS documentation demands, and developing compliance processes that reduce risk while improving audit readiness.
The program equips professionals with the tools needed to anticipate IRS focus areas, mitigate exposure, and guide clients confidently through an increasingly assertive enforcement environment.
Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2029 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
Publication Date: February 2026
Designed For
CPAs, Tax Preparers, Enrolled Agents, and other tax professionals who provide tax compliance services for individuals, partnerships, corporations and high net worth individuals
Topics Covered
- IRS enforcement priorities and initiative updates for 2026
- Trends in IRS focus areas: cryptocurrency, foreign accounts, cross‑border structures, and cannabis industry reporting
- Navigating LB&I and SBSE coordinated audits using practical documentation and communication strategies
- Recent Supreme Court and Tax Court decisions affecting regulatory authority and penalty enforcement
- Best practices for taxpayer compliance and risk mitigation in high‑visibility enforcement areas
Learning Objectives
- Identify the IRS’s primary compliance and enforcement priorities for 2026 across individual, business, and international tax areas
- Analyze IRS coordinated audit strategies (LB&I and SBSE) and apply best practices for navigating examinations effectively
- Evaluate emerging IRS target issues—including digital assets, foreign financial assets, and cannabis industry reporting—and anticipate audit techniques
- Apply strategies for assessing, managing, and challenging accuracy‑related and procedural IRS penalties
- Interpret new and significant case law affecting Treasury regulations, IRS authority, and penalty enforcement
Level
Overview
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructors
Lippes Mathias
Navigators. Way Finders. Problem Solvers. It’s who we are, what we do, and how we approach law differently at Lippes Mathias. We’re inquisitive. We think ahead, and around corners, for our clients. It’s how we find answers to legal questions that advance business outcomes – not endless options and choices. Because we know working together to understand our clients’ needs will move their businesses forward. We’re collaborative. Ability before title; tenacity before tenure. The only way to keep growing and thriving is to build our firm from within. Here, partners teach associates how to grow meaningful client relationships. Associates bring partners new business ideas to navigate together. It’s an invaluable two-way street that continually paves the path of our firm’s growth. We’re supportive. We respect you and your life, your loved ones and your commitments. Work-life balance does exist, and we value it. This is our compass. It’s why we can tell you about the Lippies Difference, and how we’re different from most other firms, but it’s better to discover for yourself.
Randall P. Andreozzi
Mr. Andreozzi’s legal career has focused on resolution of complex tax controversy matters, large case (corporate) tax matters, tax shelter litigation, employee welfare benefit litigation, and international/territorial tax issues.
For 16 years, Mr. Andreozzi worked for the IRS Office of Chief Counsel, where he served as Industry Counsel for the Commissioner’s Industry Specialization Program (ISP). He evaluated and litigated tax cases presenting Welfare Benefit Plan issues. Mr. Andreozzi litigated many seminal cases in this area, including General Signal Corp. v. Commissioner, Booth v. Commissioner, Parker Hannifin Corporation v. Commissioner, Square D Co. v. Commissioner and Neonatology Associates v. Commissioner. He also assisted and counseled other IRS attorneys and revenue agents in their development of cases under the ISP program, offering valuable expertise in areas involving tax shelters and the corporate income tax consequences of VEBAs and Welfare Benefit Plans.
During his years with the IRS Chief Counsel’s office, Mr. Andreozzi cultivated a strong reputation with attorneys and agents throughout IRS, as well as with outside tax practitioners nationwide. His extensive trial experience extends to other complex tax areas as well. Mr. Andreozzi tried a variety of complex precedential cases that have established important precedent in the areas of abusive tax shelters, corporate acquisitions (INDOPCO v. Commissioner), international taxation, United States Virgin Islands territorial taxation, and TEFRA partnerships.
Now in private practice with the firm of Lippes Mathias LLP, Mr. Andreozzi continues to focus his practice on complex tax litigation and tax controversy resolution. His practice areas include international taxation and foreign bank account reporting, criminal tax and financial crime defense, employee benefit taxation, tax shelter litigation, and a variety of emerging areas of federal and state tax law.
Mr. Andreozzi has published numerous articles on taxation, and frequently lectures on a variety of current and developing tax issues. He is an Adjunct Professor at the State University of New York (SUNY) at Buffalo School of Management, where he teaches Business Law at both the graduate and undergraduate levels. While he was with the IRS Office of Chief Counsel, he trained Chief Counsel trial attorneys at national litigation schools.