Resolving Federal Tax Controversies: Audits, Appeals and Litigation (On-Demand)

Course Description

This course will provide attorneys, CPAs and enrolled agents with a comprehensive and practical guide to navigating an IRS audit, understanding the IRS Appeals process and how to select the appropriate venue to litigate a tax claim. The course will discuss recent changes regarding the IRS Independent Office of Appeals, alternative dispute resolution options and the importance of preserving the attorney-client privilege and maintaining confidentiality when providing tax advice.

Principles

• IRS Audits
• IRS Appeals
• Alternative dispute resolution
• Tax litigation and venue selection
• Privilege Communications

Syllabus

1. IRS Audit
   • • Audit Selection
     • Scope of audit and discovery
     • 30-Day Letter
2. IRS Appeals
   • • Written Protest
     • Hearing
     • 90-Day letter
3. Alternative Dispute Resolution
   • • Pre-Filing
     • Post-Filing
     • Post Exam
4. Tax Litigation – Venue Selection
   • • United States Tax Court
     • United States District Court
     • United States Court of Federal Claims
5. Privilege Communications
   1. • Attorney-Client Privilege
      • Federally Authorized Tax Practitioner Privilege

Instructor

Richard Nessler, Esq.