Taxpayers’ Defense Conference 2011
Presentations and Workshops -- Session by Session Outline*
Session One: The IRS in Real Time · What’s in store for taxpayers given our headlong rush into more debt? With the agency’s enforcement budget at an all time high and more agents on the way, learn what this means to taxpayers.
Session Two: The New Lien Filing Rules · Liens and levies are on the rise despite IRS claims of helping citizens avoid liens. We review the new lien guidelines and explain arguments to remove liens under these rules.
Session Three: Understanding Alter Ego/Nominee Issues · The IRS is getting more aggressive with third-party levies, attacking LLCs, trusts and other entities with alter ego and nominee claims. Learn the how to effectively deal with alter ego issues.
Session Four: Mock Trial on Alter Ego Issues · We present a full scale mock legal argument on the alter ego issue. Based upon a set of hypothetic facts, two of our most experienced trial attorneys will argue the case. Mac MacPherson will play the role of a Justice Department attorney. Paul Tom will play the role of defense counsel. We’ll get a unique look at how these cases are presented.
Session Five: Appeals, Protest Letters and Form 872, ASED Waiver · We will review the procedures for executing audit appeals. A key element will be the impact of signing or not signing IRS Form 870, Waiver of Assessment Statute of Limitations. Confusion surrounds it because of IRS misstatements about the impact of not signing.
Session Six: Dealing with Dissipated Assets in OIC Negotiations · One of the most common problems with negotiating Offers in Compromise is the IRS’s practice of increasing the OIC amount with a phantom calculation called “dissipated assets.” Dan goes through the case law and Internal Revenue Manual to show you exactly how to prevent this IRS tactic from standing in the way of making a deal.
Session Seven: Recovering Fees and Costs · Most people don’t know that you can make the IRS pay your client’s fees and costs when you win. We analyze the statute and procedures for recovering fees and costs.
“This conference is cutting-edge taxpayer defense advice from the best in the country. Don’t miss it! It’s hot, on topic and you won’t fall asleep—guaranteed! Paul T. – Attorney
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