Published on March 4, 2014
IRS Practice Techniques and Case Studies Presented by Sidney Goldin, CPA, MS Taxation
Two Areas of Practice Within the IRS Framework • Audit Representation • Collection Defense
A. Audit Representation and Other Liability Cases 1. Routine Examinations 2. 1040X (Amended Return Exams) 3. Offer in Compromise (OIC) Liability Cases 4. Trust Fund Liability Cases – Appeals – No Lien Filings
A. Audit Representation and Other Liability Cases (cont’d.) 5. Community Property Split Disputes Between Spouses 6. Innocent Spouse Cases 7. Transferee Liability Cases (Section 6901) 8. Penalty Liability (Defense)
A. Audit Representation and Other Liability Cases (cont’d.) 9. IRS Transcript Errors and Issues 10. Other Types of Issues Not Covered Above a. Failure to honor levy b. Forcible rescue of seized property
B. Audit Defense Techniques 1. Exam Interviews – Power of Attorney Factor 2. No Interview with Client 3. Client’s Lack of Records – Agent’s Attempt at Reconstruction of Records Form 4822 Response –
B. Audit Defense Techniques (cont’d.) 4. No Show Client a. Field Audits b. Office Audits c. Correspondence Audits
B. Audit Defense Techniques (cont’d.) 5. Three Year Assessment Statute Issues (ASEDs) a. Significance of statute to agent (1) Leveraging/Manipulating against agent b. statute Consents to extend statute – to sign or not to sign – that is the question
B. Audit Defense Techniques (cont’d.) 6. Consideration for Technical Advice Memorandum Request (TAM) Request to IRS National Office 7. Conclusion of Exam a. 30 day letter b. 90 day letter (Statutory Notice of Deficiency)
C. Collection Defense Cases/Issues 1. Self Reported/Assessed Unpaid or Underpaid Income Tax 2. Additional Tax Due as Result of Audit 3. Employment Tax Cases – Trust Funds
C. Collection Defense Cases/Issues (cont’d.) 4. Failure to File Tax Returns (1040, 941, etc.) 5. Notices 6. Final Notices
C. Collection Defense Cases/Issues (cont’d.) 7. CDP Requests and Equivalent Hearings 8. Levy (continuous and one-time) – Issues 9. Trust Fund Letters and 4180s
D. IRS Collection Defense Strategy 1. IRS Revenue Officer Visits a. Usually unannounced (1) Normal abuses (2) Counter-Measures/ Defense
D. IRS Collection Defense Strategy (cont’d.) 2. By-Passing Power of Attorneys a. Counter-Measures 3. Filing of Collection Due Process (CDP) Request 4. Equivalent Hearing
D. IRS Collection Defense Strategy (cont’d.) 5. Ten Year Collection Statute (CSEDs) a. Issues for revenue officers (1) Consents to extend collection statutes (again – to sign or not to sign)
D. IRS Collection Defense Strategy (cont’d.) 6. Intervening Events that Toll 10 Year Statute and Allow IRS More Time to Collect Tax a. Example – Recent unnecessary (erroneous) bankruptcy with client by bankruptcy attorney b. Three year wait to file bankruptcy filed (1) OIC’s do not toll this statute
D. IRS Collection Defense Strategy (cont’d.) 7. Collection Appeals Program (CAP) – When All Other Remedies Are Exhausted
If you have any questions, please feel free to contact Sidney: 214-635-2509 firstname.lastname@example.org
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