2023 IRS Updates on Penalty Abatement Requests and Litigation

Learn the various types of penalties that the IRS may assert and how to litigate them!

The IRS asserts millions of dollars in tax penalties against taxpayers each year. This webinar by tax attorney Adam Fayne, will discuss on how to represent your client and seek abatement and removal of IRS penalties. You will learn about Reasonable Cause exceptions to penalties, the First Time Penalty Abatement procedures, various methods to request penalty abatement (e.g. in exam, appeals, post-appeals, Collection Due Process), and how to litigate penalty abatement requests when you are unsuccessful in the examination, administrative, or appellate stage. Adam will also discuss the various types of penalties that the IRS may assert against your client.

Webinar Objectives

This session will provide insight and tools to assist you and your clients understand what penalties may be asserted if certain actions are taken, or not taken. You will learn how to dispute penalties at the various stages of a penalty lifecycle; e.g. examination stage, appellate stage, collection stage, and refund stage. Lastly, you will learn about the ability to dispute penalties administratively and through formal litigation in Tax Court and District Court.

Webinar Highlights

• The various penalties the IRS could assert against a taxpayer, including penalties related to foreign assets.
• Contesting Penalties in Examination
• Contesting Penalties in Appeals
• Contesting Penalties in Collection Due Process
• Contesting Penalties in Tax Court
• Contesting Penalties in District Court
• Automatic vs Discretionary Penalties
• Reasonable Cause exception to Penalties

Who Should Attend

• Accountants
• Tax Preparers
• CFOs
• Financial Compliance Professionals
• Lawyers