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INTRODUCING...

Problem Solver CD Set Dan Pilla’s IRS Problem Solver Series

The Associated Press once said that Dan Pilla probably knows more about the IRS than the commissioner. Now here’s your opportunity to tap into Dan’s 30 years of experience in solving IRS problems. Dan Pilla’s IRS Problem Solver Series is a five-part audio presentation that brings to life the #1 tax book in America, The IRS Problem Solver. This series consists of Dan’s book, plus five audio CDs and one CD containing a 26-page workbook-six CDs in all.

In The Problem Solver Series, you’ll learn:

How to set up and properly use independent contractors for your small business
If you have a small business, one of the most effective ways to keep costs down is to use independent contactors. But you need to know exactly  how to do it. This session gives you the details on how set up a proper relationship, how to create a contract and how to make sure your independent contractors are never challenged by the IRS.

How to turn your hobby into a business without running afoul of the IRS.

In this economy, more and more people are looking for ways to supplement their incomes. By following the simple rules clearly explained in this session, you’ll learn exactly how to earn income from your hobby and how to claim all the tax deductions you’re allowed. It’s now more important than ever to cut your taxes and here’s how you do it.

How to audit-proof and penalty-proof your tax return.
With tax audits on the rise and the government looking for more money every day, you have to know exactly how to protect yourself from the IRS. Nobody wants to get audited and Dan’s exclusive strategies for audit-proofing and penalty-proofing your tax return will keep the IRS off your back and out of your life.

How to respond to the most common IRS computer notices.
The IRS mails tens of millions of notices every year and not even the IRS can get it right. But Dan’s vast experience means that you’ll never fall victim to another bogus IRS notice again. After listening to this session, you’ll exactly what kind of notice you have and exactly how to handle it. According to Dan’s research, almost half of every notice the IRS sends is wrong. So don’t allow yourself to be taken advantage of when the solution is this simple.

Secrets to dealing with IRS audits and appeals.
Dan’s research shows that the IRS is dead wrong in its audit results between 60% to 90% of the time. And while people fear audits, the fact is, auditors have no power over you whatsoever. In this session, Dan reveals his secrets to effectively dealing with the IRS that he’s perfected in over 30 years of helping people through tax audits.

How to cancel penalty and interest assessments.
Penalty and interest assessments are responsible to doubling, tripling, even quadrupling IRS tax bills. But did you know that every penalty can be canceled if you make the proper argument to the IRS? Well it’s true and in this session, Dan’s shows you exactly how to take the simple steps that can save you a fortune. Even if you don’t have a tax bill, you need to know about these strategies because each year, the IRS assesses over 30 million penalties. Your chances of getting hit are about 1 in 4.


And that’s not all. Dan’s book The IRS Problem Solver is packed with much, much more. You’ll get the kind of information you’ll simply never learn from the IRS or anywhere else for that matter. There simply is no other person in America with more experience in dealing with the IRS than Dan Pilla.

That’s why Dan’s book, The IRS Problem Solver was hailed as the best tax book in America.

Now, with The Problem Solver Series, you’ll be guided by the hand through important tax-saving strategies and the critical steps all taxpayers need to take to protect themselves from an increasingly aggressive IRS. The IRS Problem Solver package consists of Dan’s 299-page book, five audio CDs and Dan’s 26-page workbook also on CD. The workbook contains his full lecture notes and all the references you need to stay on solid footing when dealing with the IRS.

Order your copy of The IRS Problem Solver series now. Get all six CDs and Dan’s book for just $115.00, plus $6.95 Priority S/H. ORDER NOW!   

If you already have the book, you can get just the CD set for $99.95, plus P&H. ORDER NOW!

TAX FREEDOM INSTITUTE

and

WINNING PUBLICATIONS present

 

TAX SOLUTION SEMINARS

featuring Daniel J. Pilla, Tax Litigation Consultant

 

Are you tired of living with IRS problems?

Tired of paying too much in taxes?

 

TAX SOLUTIONS SEMINARS have helped thousands of others and can help you, too! The IRS is back in the collection business and collection actions are quickly returning to historic levels. If you currently have a tax problem with the IRS,

Now is the time to get that problem solved!

New rights and procedures under the restructured IRS make tax debt settlement easier now than ever. The return of the IRS to "business as usual" with regard to collecting delinquent taxes makes resolving your problem more crucial than ever.

Tax Solutions Seminars promise to be information-packed conferences that can can help you whether you have a problem, want to avoid problems or want to make sure you're not paying more taxes than you owe.

Seminar topics include tax-saving strategies and tax debt remedies. You'll also have the opportunity to speak with Dan Pilla or one of his Tax Freedom Institute Tax Professionals about your situation.

Couldn't make the seminar?

 

The Tax Solutions Seminar DVD is available! $19.95 Order Now!

 

 

Dan Pilla's Available CDs DVDs and Videos

MORE INFO

The IRS Problem Solver CD Set

The Associated Press once said that Dan Pilla probably knows more about the IRS than the commissioner. Now here’s your opportunity to tap into Dan’s 30 years of experience in solving IRS problems.

This Five-part Audio Presentation that Brings the Nation's #1 Tax Book to life!

Dan Pilla’s IRS Problem Solver Series is a five-part audio presentation that brings to life the number 1 tax book in America, The IRS Problem Solver. This series consists of Dan’s book on five audio CDs plus one CD containing a 26-page workbook -six CDs in all.     Order Now! $99.95

SAVE!  Order the IRS PROBLEM SOLVER PACKAGE which includes the CD set and Problem Solver book!
 
                            Order Now! $115.00

 

2015DefConCDSet

MORE INFO

 

Taxpayers' Defense Conference CD Sets
(5-7 CDs per set or USB MP3 format available)

Dan provides up to ten hours of live presentation on the latest developments in our tax laws and taxpayers' rights. The annual Taxpayers' Defense Conference takes place each fall.
                                      
2016: Installment Agreement Negotiations
Order Now! $149.00
2015 Offer in Compromise- Start to Finish
 Order Now! $149.00
2014 Collection Due Process "Our Jewel"
Order Now! $149.00
 2013 Robust and Sophisticated Enforcement
Order Now! $149.00
 
2012 IRS - The Face of National Healthcare
Order Now! $149.00
 2011 The IRS in Real Time
Order Now! $149.00

Click here for session details of each audio set
Need continuing education credits? More Info 

Save! Order both 2015 & 2016 audio sets and save $50.00!
Order Now!  $248
(Note these sets do not include CE credits)

Prior year audio may also be available - call us to order. (800) 553-6458

MORE INFO

Tax Solutions Seminar DVD

Every year, around the country, Dan conducts public seminars on effective strategies for cutting taxes and solving tax problems. If you were not able to attend one of these you can now get the seminar on DVD!
Order Now! $19.95

Stairway to Freedom (DVD)

How to solve your IRS problems without the high cost of professional help. Learn your five most sacred taxpayer rights, how to prevent IRS problems before they start, how to negotiate effectively with the IRS, how to cut taxes, how to claim more deductions, and how to be forgiven for back tax debt.
Order Now! $19.95

 

Refund Policy: DVDs and  CDs returnable only if unopened. Refunds do not include shipping. *
                      Orders under $75 will not be refunded if free consultation is used.
Shipping: Books and products will be shipped within 3 business days of order recieved vis USPS Priority and to arrive within 10 business days to a correct address.

 

 


 

Daniel J Pilla, the nation's leading Tax Litigation Consultant, yearly puts on a Taxpayers Defense Conference.  As a Tax Litigation Consultant and author of over a dozen books on IRS defense strategies, Dan has been on the cutting edge of taxpayers’ rights defense for over three decades.

Every year, Dan puts on a two day conference to discuss the latest in IRS problem solving ideas and strategies, as well as the lates rules and procedures for dealing with the IRS. Dan’s thorough, informative and easy-to-follow presentations are a must for any tax professional. Tax Professionals will find the information invaluable for them and their clients while they also earn continuing education credits.  


  “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      

 

Click here for more information on the next conference.

 

Missed the latest Taxpayers Defense Conference? 
Each years session information below 

 

You can still get the cutting edge information by ordering a  Taxpayer Defense Conference set. 

$149 PLUS SHIPPING PER SET  

 

Each set includes audio recordings of that year's conference years topics as well as well organized outlines.

Check below for each sets agenda 

 

2016: Installment Agreement Negotiations


2015: Offer in Compromise - Start to Finish  
 

2014: Collection Due Process - "Our Jewel"
 

2013: Robust and Sophisticated Enforcement 
 

2012: IRS - The Face of National Health Care
 

2011: The IRS in Real Time
 

 2010: The IRS and the Recession

 

2 Set Special
 Buy 2 non CE sets for $248
2015 and 2016

 

                     Want other years?                      

Please contact us for availability on 2006-2009 sets
or
ability to purchase two sets other than 2015/2014


1-800-553-6458

 

 

 Please contact us for availability on 2006-2009 sets or ability to purchase 2  sets other than 2015/2014
1-800-553-6458


 

Tax Professionals - are you in need of educational credits?

We are excited to announce we are an IRS approved CE provider and now offer the 2013-on
Taxpayers Defense Conference Audio Sets with  credit hours.

 

Audio recordings, outlines and CE quizzers for CE credits available in each set. 

ONLY $225 PLUS SHIPPING PER SET     


2016: Installment Agreement Negotiations with 8 CE Credits- 1 Ethics, 7 General 


2015: Offer in Compromise - Start to Finish with 10 CE Credits- 2 Ethics, 8 General


2014: Collection Due Process - "Our Jewel" with 9 CE credits


2013: Robust and Sophisticated Enforcement with 8 CE credits

 

 

 


Taxpayers Defense Conference Session Descriptions 

 

2016 Taxpayers Defense Conference  Installment Agreement Negotiations

Session One: The IRS in Crisis
Dan Pilla addresses the current problems with IRS administrative issues due to budget and staffing cuts. We discuss computer security problems, correspondence processing, and appeals case backlog. We address ways to navigate around these obstacles.

Session Two: Understanding IRS Transcripts
Explanation and analysis of the various computer transcripts and codes the IRS uses in the processing of all cases. Understanding these transcripts is an essential element of determining the posture of a given case and the procedures necessary to work to a resolution.

Session Three: How to Stabilize Collection
Dan Pilla explains exactly how the IRS begins enforced collection action in a given delinquency case, and exactly how to keep a case from progressing from the initial notice stage to the levy stage. Dan will explain the IRS’s Automated Collection Service procedures and how to deal with a revenue officer assigned to collect a tax. Focus will be on IRS code sections 6159 and 6343, regarding installment agreements and the prevention of levy and seizure actions.

Session Four: How to Establish an Installment Payment
Dan Pilla provides a full analysis of the IRS’s installment agreement rules, including analysis of relevant code sections and the Internal Revenue Manual. There will be heavy emphasis on determining what constitutes allowable living expenses for the purposes of determining the installment agreement amount.

Session Five: The Partial Pay Installment Agreement
Steve Klitzner, Attorney, analyzes the tax code and provisions of the Internal Revenue Manual that allow the IRS to enter into a two-year installment agreement that only partially pays the tax, which is the so-called Partial Pay Installment Agreement. We discuss the requirements that must be met for inclusion in the program, the forms and procedures needed to get a client approved, and the IRS’s requirement for ongoing financial analysis once the client is included in the program.

Session Six: Live Roll-playing of Installment Agreement Negotiations  (not recorded)
The attendees will be broken into eight separate groups and each group will be presented with a set of facts regarding a hypothetical delinquent taxpayer. All the facts are derived from actual cases. The group will determine the best course of action for attempting to negotiate a collection hold and establish an installment agreement, based on all the teachings of the previous day’s sessions. Each group will feature an experienced tax pro playing the part of an IRS officer.

Session Seven: Evaluation and Critique of Role-playing Sessions
Dan Pilla, Donald MacPherson, Attorney,  and Paul Tom, Attorney will review, critique and analyze each of the mock negotiation sessions. We will analyze the strengths and weaknesses of each presentation, evaluate the performance of each participant and discuss potential alternative approaches under the circumstances. We will also address ethical issues, including potential conflicts of interest, given the facts of the case.

Session Eight: Ethical Considerations in Installment Agreement Appeals
Dan Pilla discusses the many ethical considerations in play when contemplating an installment agreement appeal. Most importantly of all the factors, an installment agreement appeal tolls the IRS’s collection statute of limitations, effectively giving the IRS more time to collect. We analyze the statutory tolling provisions (there are five them) which most tax pros are simply unaware of. IRS rules are specific and detailed on ethical issues in such cases, including income and asset disclosures, tax compliance with current and future filing and payment responsibilities, and counsel’s responsibility to provide accurate information. We also address the potential penalty under code section 6702 that applies to any “frivolous submission” to the IRS, which by law includes an Installment Agreement.

Session Nine: Moderated Discussion (not recorded)
Group discussion of problems, questions and strategies based upon all earlier presentations. We will present and discuss hypothetical cases involving various aspects of IRS negotiations.

Dan Pilla’s lectures have been accredited by the Penn State Tax Institute, the Minnesota Chapter of Certified Public Accountants, the Minnesota Society of Enrolled Agents and the Minnesota Chapter of the National Association of Tax Professionals.

Steven Klitzner is an attorney licensed by the States of Florida. He practices tax law in Florida and is admitted to the United States Tax Court. Steve has been a Consulting Member of the Tax Freedom Institute since 2002 and has been a past instructor at Tax Freedom Institute functions.

 

2016: Installment Agreement Negotiations Audio Set   $149 pus S/H


2016: Installment Agreement Negotiations with 8 CE Credits- 1 Ethics, 7 General 

$225 pus S/H

 

 


 

2015 Taxpayers Defense Conference  Offers in Compromise - Start to Finish

 

Session One: The Offer in Compromise The Offer in Compromise (OIC) is the IRS’s flagship settlement program. We discuss the four types of offers, the fact scenarios behind each one, the two different administrative procedure tracks for OICs, and we examine the forms and worksheets necessary to present and argue an OIC. We discuss the important strategy of using the Collection Due Process channel as the single best means to present an OIC. This strategy will give you the most leverage in getting your OIC accepted.

Session Two: Figuring Reasonable Collection Potential  We discuss and explain of the essential element of the OIC, which is the taxpayer’s “reasonable collection potential.” We discuss the IRS’s extensive Internal Revenue Manual (IRM) provisions on this subject, including an analysis of the IRS’s fixed standards for living expenses. Most importantly, we explain how to defeat the arbitrary application of the IRS’s housing and transportation standards, something that bites taxpayers in nearly every OIC.

 Session Three: How to Handle an OIC Hearing and Live Role-playing   Last year, our live role-playing sessions were a massive hit. We will do the same thing this year. First, Dan Pilla explains exactly how an OIC hearing is conducted from both the perspective of the IRS and the taxpayer. He will address how to set up and present a case and how to present facts and evidence to an OIC examiner. This session includes live, mock OIC hearings in which the participants will function as counsel representing a taxpayer’s case before an OIC examiner. Experienced TFI members will assist with the mock hearings, functioning as OIC examiners. The hearings will be based upon several sets of hypothetical facts common to tax delinquency cases.

Session Four: Evaluation and Critique of OIC Hearings  Dan and the OIC examiners will review, critique and analyze each of the mock hearings. We will analyze the strengths and weaknesses of each presentation, evaluate the performance of each participant and discuss potential alternative approaches under the circumstances. This is a highly educational process, as all participants will provide insight into their experience in the hearing.

Session Five: Effective Tax Administration and Special Circumstances  Dan addresses the IRS’s so-called “Effective Tax Administration and “Special Circumstances” OICs. These are offer opportunities made available by IRS regulations that allow a person to present an offer in circumstances where he might not otherwise qualify. We examine the IRS’s regulations and the IRM provisions that govern this procedure. Knowledge of procedures is essential as it will give you opportunities to resolve even the most difficult cases.

Session Six: Dealing with Dissipated Assets  Dan addresses the special rules that apply to citizens with fixed assets when entering into an OIC. Examples include liquid cash, retirement accounts, cash value of insurance policies, etc. IRS administrative procedures and Tax Court case law is specific on how such assets are to be considered and valued in an OIC, and these authorities address the consequences of a taxpayer liquidating such assets for less than fair market value prior to submitting an OIC.

Session Seven: “Not in the Government’s Best Interest”  Dan discusses the many ethical considerations of an OIC. IRS rules are specific and detailed on ethical issues, including income and asset disclosures, tax compliance with current and future filing and payment responsibilities, and counsel’s responsibility to provide accurate information. We address the detailed IRM provisions that allow the IRS to reject an OIC that might otherwise qualify for acceptance if acceptance is “not in the government’s best interest.” We also address the potential penalty under code section 6702 that applies to any “frivolous submission” to the IRS, which includes an Offer in Compromise.

Session Eight: Moderated Discussion  Group discussion of problems, questions and strategies based upon all earlier presentations. We will present and discuss both hypothetical cases involving CDP administrative and judicial appeals. If you have a problem case, bring it to the defense conference. You will go home with a solution. This is often the most creative part of the conference, as experienced TFI members provide suggestions and ideas for solving even the most difficult problems.

 

2015: Offer in Compromise - Start to Finish  (no credits) $149 plus shipping
   

 

2015: Offer in Compromise - Start to Finish with 10 CE Credits- 2 Ethics, 8 General 
$225 plus shipping  

 

 


 

2014 Taxpayers Defesne Conference: Collection Due Process - “Our Jewel”

  

The IRS Strategic Plan   Dan will review and explain the IRS’s 2014-2017 strategic plan. This plan lays out the IRS’s strategies regarding audits, collection and tax law enforcement in general. We discuss the IRS’s policy and strategy changes that will affect how the IRS enforces the law in the foreseeable future.

 

The Collection Due Process Appeal--Generally  The right to a Collection Due Process (CDP) appeal is among the most important and powerful rights enjoyed by taxpayers. The more you understand about these rights, the more leverage you have to prevent harmful collection action (such as levies and seizures) and the better chance you’ll have of negotiating a reasonable settlement. Dan explains the CDP lien and levy appeal rights under code sections 6320 and 6330. We address the timely filing of CDP appeals, issues that can and cannot be addressed in CDP appeals, and the burden of proof in CDP cases. 

 

How to Handle a CDP Hearing and Live Role-playing Dan explains exactly how a CDP hearing is conducted from both the perspective of the IRS and the taxpayer. He will address how to set up and present a case and how to obtain discovery from the IRS prior to the CDP hearing. This session will include live, mock CDP hearings in which the participants will function as counsel representing a taxpayer before an IRS hearing officer. Certain participants will play the roles of IRS settlement officers. The hearings will be based upon several sets of hypothetical facts common to tax delinquency cases.

 

Evaluation and Critique of CDP Hearings Dan and those performing as settlement officers will review, critique and analyze each of the mock hearings. We will analyze the strengths and weaknesses of each presentation, evaluate the performance of each participant and discuss potential alternative approaches under the circumstances. We will also address ethical issues, including potential conflicts of interest, given the facts of the case. This session will be a tremendous opportunity to prepare for and participate in a CDP hearing under the tutelage of highly skilled and experienced tax pros.

 

Proving Abuse of Discretion in CDP Appeals  In this session, Dan addresses recent case law issued by the United States Tax Court on the question of the taxpayer’s burden of proof in CDP appeals. We evaluate both winning and losing cases and discuss the body of evidence needed to prevail in the case.

 

The CDP Judicial Appeal  Adverse CDP decisions are appealable to the United States Tax Court. This is a key reason why a properly prepared tax pro has great leverage in CDP cases. In this session, Dan addresses the specific procedures for a judicial appeal of an adverse CDP decision. He explains the Tax Court’s jurisdiction and lays out the essential elements of a Tax Court Petition for review of a CDP determination. He also explains the manner in which CDP cases are resolved by the Tax Court, including remands, summary judgment and court trials.

 

CDP Employment Tax Appeals  Here Dan discusses the special rules that apply to CDP appeals involving delinquent employment taxes, including the collection stay provisions of code section 6330, the Trust Fund Recovery Penalty and other related issues.

 

Moderated Discussion  Group discussion of problems, questions and strategies based upon all earlier presentations. We will present and discuss both hypothetical cases involving CDP administrative and judicial appeals. 

 

MISSED 2014? We offer audio sets of the 2014 conference 

2014: Collection Due Process - "Our Jewel"  $149 plus shippping
 

2014: Collection Due Process - "Our Jewel" with 9 CE credits $225 plus shipping

 


 

2013 Taxpayers Defense Conference: “Robust and Sophisticated Enforcement”

Outlook on IRS Enforcement Actions - “Robust and Sophisticated Enforcement”    Dan Pilla reviews the most recent plans of the IRS regarding audits, collection and tax law enforcement in general. He discusses IRS’s policy and strategy changes that will affect how the IRS enforces the law.

 “First Time Failure” Penalty Abatement Rules   Dan reviews the IRS’s new policy providing for automatic abatement of delinquency penalties in certain cases. He reviews all the rules and procedures necessary to take advantage of this policy, including the rules for businesses and the frivolous submissions penalty. He also discusses the appeals procedures involving the assessment of these penalties. 

Offshore Voluntary Disclosure Program    Dan explains the details of the IRS’s Offshore Voluntary Disclosure Initiative. This is the IRS’s program of “voluntary disclosure” that allows certain taxpayers to disclose their prior use of foreign bank accounts, pay delinquent taxes and reduced penalties, and thereby avoid criminal prosecution and additional penalties for failure to report foreign income and pay the taxes. This is a critical issue for many taxpayers but the IRS’s policies have many people “frozen in place” because they don’t know how to proceed. 

Considerations in Potential Criminal Cases   One of the nation’s most experienced criminal tax defense attorneys, Donald (Mac) Macpherson reviews the strategies that must be followed in cases where the client’s facts suggest a potential for criminal investigation or prosecution. We examine the statutory limitations to the tax preparer privilege, the nature of and process for setting up Koval agreements, how to evaluate the client’s options in such a case, and more. 

Critical Developments in Tax Bankruptcy Cases  Tax Attorney and bankruptcy expert Paul R. Tom presents a discussion on the developments in the law of the rules regarding the discharge of federal income taxes in bankruptcy. Of particular interest are the cases of Hindenlang and McCoy, both circuit court opinions directly impacting the extent to which taxes can be discharged in non-filer cases. This information is vital in the context of developing effective strategies when facing collection problems.

The Volunteer Classification Settlement Program  Dan explores the IRS’s program of seeking advance classification of a company’s “workers.” This program is designed to allow companies intending to use independent contractors to seek an advance ruling from the IRS of whether those workers will in fact qualify under the law as independent contractors. By using this program, companies can avoid the uncertainty and risk involved with using independent contractors in potentially questionable circumstances. 

Proving a Home Office Deduction   Dan discusses the new rules allowing for a home office “standard deduction.” He also reviews the rules and procedures for claiming and proving a home office deduction, whether using the new “standard deduction” or using the traditional method of proof. 

The New Appeals Procedures – Bonus Session  Tax Attorney Steven Klitzner goes over the Appeals Office Memo on the AJAC Project and how it will affect appeals in the future.

This year, besides Dan Pilla, our guest seminar speakers were Donald (Mac) MacPherson and Paul R.Tom.
Mac is an attorney licensed in the State of Arizona and California. He has practiced law for more than thirty-five years. He is board certified in tax and criminal law. He is also admitted to practice before the United States Tax Court. 

Paul is an attorney licensed by the States of Oklahoma and Arkansas. He practices tax and bankruptcy law throughout Oklahoma and is admitted to practice before the United States Tax Court. Both Mac and Paul are Consulting Members of the Tax Freedom Institute and have been for years. Both have been past Taxpayers Defense Conference instructors.

  

MISSED 2013?  We offer the following Audio Sets of the 2013 conference.  

                         2013: Robust and Sophisticated Enforcement $149plus shippping

2013: Robust and Sophisticated Enforcement with 8 CE credits $225plus shipping

  

                                     


        Order prior year CD sets (2006-2012) for just $149 plus $10 shipping.  Look below for previous years topics.

2012 Taxpayers Defense Conference: IRS – The Face of National Health Care

 IRS—The Face of National Health Care   Dan Pilla reviews the tax aspects of the Patient Protection and Affordable Care Act (PPACA) and in particular, how the IRS will interact with the public in enforcing the individual and business penalties under the Act.

 Understanding Penalties Under the PPACA   A detailed examination of the penalties under the PPACA, including the exceptions and exemptions applicable to individuals and "small businesses." Dan also discusses the appeals procedures involving the assessment of these penalties. 

Challenging the Assessment Process   Criminal Tax Attorney Donald MacPherson discusses the statutory and case law regarding the IRS's assessment authority and procedures. He explains how to verify whether assessments by the IRS are properly supported by the appropriate administrative procedures required under the law. We also discuss important ethical considerations that arise when challenging an assessment. 

Prosecuting an Offer in Compromise   In May 2012, the IRS made sweeping, significant changes to how to evaluates Offers in Compromise. Dan reviews these changes and provides case examples of how they apply. We also evaluate essential ethical considerations in submitting and arguing Offers in Compromise to the IRS.

Prosecuting a CAP Appeal   Attorney Steven Klitzner presents a discussion on when and how to use the IRS's Collection Appeal Program (CAP). This appeal is available in any collection situation, such as a wage or bank levy. We review the regulations and IRS guidance on utilizing the program. 

Determining the Priority of Federal Tax Liens  Dan examines the rules for determining whether a federal tax lien has priority over the claims of other creditors. This is important for determining a person's "reasonable collection potential" in Offer in Compromise cases. We also address the question in the context of fees paid to tax professionals. 

Conflicts of Interest in Joint Representation Cases   Dan discusses the unique problems that arise when representing a husband and wife, or corporate shareholders or partners. Joint representation always involves the potential for a conflict of interest. Circular 230 requires specific steps in these cases, including disclosure to the client of the conflict.

Get the 2012 CD set with outlines  $149 plus shipping ...


 

2011 Taxpayers Defense Conference: The IRS in Real Time

The IRS in Real Time – True Big Brother  As the IRS moves closer to a paperless return system, the agency is pushing harder for real-time access to all data bases to allow it to compute a tax return without the involvement of the taxpayer. Think this is impossible? Dan Pilla talks about the IRS’s progress toward this goal, its plans for the future and how this will affect taxpayers and tax professionals.

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.

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.

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. Donald 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.

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.

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.

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. 

Get the 2011 CD set with outlines...

 


 

2010 Taxpayers Defense Conference: The IRS and the Recession

The IRS and the Recession: Promises and Reality   The IRS introduced its “Fresh Start” program with promises to help struggling taxpayers. But is the IRS living up to its promises? Dan Pilla examines the programs and procedures that are available and how the IRS is in fact administering these in real life.

Handling the “Frivolous Submission” Penalty   Congress beefed up and expanded the penalty for a “frivolous submission” and is issuing more of these penalties every day. Learn how to effectively avoid and challenge this potentially costly penalty.

Dealing with Preparer Penalties    Attorney, CPA Patti Gentile discusses the due diligence requirements imposed on tax professionals under code section 6694 and Circular 230. We review preparer responsibilities and the process of challenging a potential OPR investigation.

Protecting Independent Contractors   This section addresses the IRS’s growing attack on the use of independent contractors, and what you can do to protect yourself from it. We discuss the rules that make a valid independent contractor, drafting considerations for contractor agreements and how to challenge adverse independent contractor determinations.

The Practioner’s Basic Toolbox of Court Authority   Attorney Steven Klitzner reviews eight of the most important legal authorities in support of taxpayers’ rights. Any tax professional must know and understand this tool box of legal precedents to help in any audit or collection situation.

Tax Lien Subordination Process   Liens and levies are on the rise but Treasury auditors recently reported that the IRS does not folloe the law when issuing tax liens. Learn how to protect yourself from tax liens, including lien appeal and lien withdrawal procedures, as well as arguments to remove liens.

Deducting Education Expenses   More people are going back to school to better their education. There are host of education credits and deductions in the tax code but you need to know how to prove them. Here you’ll learn exactly what to do with educational expenses to deduct.


    Get the 2010 Conference on CD set with outlines ...


For more information on prior Taxpayers Defense Conference CD sets available, contact our office. 1 800-553-6458

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