2025 Theme:
APPEALS PLUS

What to Expect at the 2025 Taxpayers Defense Conference

The 2025 Defense Conference will focus on the Appeals Process as well as the sweeping changes brought about by recent legislation.

Topics will include:

• Analysis of new regulations regarding Appeals Office jurisdiction and procedures
• Discussion of the Appeals Office’s elusive “retained jurisdiction” in CDP cases under section 6330(d)(3)
• Non-CDP lien appeal rights under little-known, and less understood, section 6326
• Analysis of the Taxpayer Assistance and Service Act as it relates to Appeals
• Discussion and analysis of Appeals Office authority under Treas. Reg. section 601.106
• Proven techniques for presenting a case to an Appeals Officer
• Strategies and procedures for winning an award of fees and costs under section 7430
• Key elements of the One Big Beautiful Bill Act
• Our unique moderated brainstorming sessions
• This Conference will include up to 2 ethics credits
• And much, much more!

Notices: The Heart of Revitalized Enforcement  (1 hr credit)
The IRS mails over 150 million notices annually, falling into five broad categories. The IRS largely shutdown its notice programs during the COVID pandemic, but starting in January 2024, reinitiated all notice programs. We address here the five categories of notices and specifically examine how the IRS generally carries out its notice programs. We also review the IRS’s new Notice Simplification Program.

Correction Notices  (1 hr credit)
Dan Pilla presents a detailed discussion the IRS’s correction notices and procedures for responding to them. We specifically identify by notice number the most common correction notices and how to respond. We address the deficiency procedures in the IRS code, how they apply to correction notices, and the exceptions to them.

Non-filer Notices  (1 hr credit)
Dan Pilla takes an in-depth look at the IRS’s recently-launched Non-filer Initiative. We look at the notices used to communicate with alleged tax return non-filers, and how to respond them. We address the substitute for return procedures and how they relate to the deficiency procedures explained in session 2.

Examination Notices  (1 hr credit)
MacKenzie Hesselroth discusses examination (audit) notices. Heavy emphasis is placed on the correspondence audit program, under which the IRS audits tax returns thru the mail. We also review the various notices used during an active examination. We identify the specific notices used and how to respond.

Tax Court Notices  (2 hrs credit)
Dan Pilla reviews the nine specific notices the IRS uses to communicate final administrative determinations that carry Tax Court appeal rights. We identify the notices by name and notice number, and review the legal authority for each such notice. We also review the law that provides Tax Court jurisdiction to review the determination. Special emphasis is placed on the new and developing line of court decisions that establish an “equitable tolling” doctrine for Tax Court filing deadlines.

Collection Notices (2 hrs credit)
Dan Pilla defines and explains all IRS collection notices. Special attention is given to statutory final notice letters that carry Collection Due Process appeal rights, as well as lien filing notices that do the same. We also examine all collection notices that the IRS uses for refund offsets, social security levies, and third-party contacts. We also examine all collection notices related to installment agreement enforcement and revocation. We examine the appeals processes available for all these collection notices.

Understanding and Avoiding Conflicts of Interest  (1 hr ethics credit)
Steve Klitzner examines IRS Circular 230 and ABA Rules of Professional Responsibility on the issue of conflicts of interest. We discuss common potential conflict situations, including husband and wife, partnership liabilities, and Trust Fund Recovery Penalty assessments against multiple corporate employees and shareholders. We review practice aids to helping practitioners recognize and avoid conflicts.

Non-filer Voluntary Disclosure Program  (1 hr credit)
Scott MacPherson addresses the IRS’s Non-filer Voluntary Disclosure Program, which allows serial tax return non-filers to file correct returns and thus, potentially avoid criminal prosecution for failure to file. We focus on the IRS’s burden of proof in a criminal case, versus that of a civil case. We discuss how to stop a potential criminal failure to file as opposed to a common civil non-filer.

ERC Voluntary Disclosure Program  (1 hr credit)
Dan Pilla discusses the IRS’s recently-renewed Employment Retention Credit Voluntary Disclosure Program. This program allows companies that received improper ERC credits/refunds to repay the credit without penalties or interest. We discuss how to spot a potential criminal ERC claim as opposed to a claim based on a good faith error or misunderstanding of the law.

Client Confidentiality Compliance  (1 hr ethics credit)
Dan Pilla examines IRS Circular 230 and related publications that set forth the standards tax pros must follow to maintain client confidentiality. In particular, we address the minimum steps that must be taken to ensure electronic security and what to do if a tax pro’s computer systems are hacked. We also identify the most current pfishing scams to be aware of.

Moderated Discussion with Q&A
Dan Pilla will moderate group discussion of problems, questions, and strategies based upon all earlier presentations. We will present and discuss actual cases involving various aspects of IRS problems resolution.

Total credit hours up to  14 credits  including  2 hours ethics credits.