Taxpayers Defense Institute,

Pilla Tax Academy
Daniel J. Pilla

present the 

 Taxpayers Defense Conference


The Nation’s Top IRS Conference for Tax Professionals


2023 Taxpayers Defense Conference

Thursday & Friday
October 26th & 27th



Location: Tampa Florida
Embassy Suites by Hilton
Tampa Airport Westshore

Limited rooms book your room now!


SAVE $100 if Register by Sept 1, 2023

 $895 $795 Onsite Attendee Registration

$895 $795 Virtual Live Attendee Registration

Additional discounts available for
Taxpayers Defense Institute Members
Join us!

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2023 Sessions Detail

023 Sessions


    • What to Expect from the Revitalized IRS (1 hour)
      The Inflation Reduction Act guaranteed $80 billion in additional funding to the IRS but recent legislation cut $21 billion from that package. The agency just released its Strategic Operating Plan laying out how it will use the new resources going forward. Dan Pilla addresses how this will affect taxpayers generally, and small businesses specifically.
    • Penalty Abatement Law and Procedures (2 hours)
      Dan Pilla presents a detailed discussion on the most common penalties assessed against taxpayers, and strategies for getting penalty relief. We analyze statutes, regulations and court decisions that bear on penalty relief. We discuss penalty appeals in both the administrative context and in Collection Due Process (CDP) appeals.
    • Recurring Issues in CDP Cases (2 hours)
      Dan Pilla takes an in-depth look at several recurring problem issues that arise in CDP cases. Drawing on Pilla’s experience as lead counsel in dozens of CDP cases litigated in the U.S. Tax Court, we analyze the mistakes made by IRS Appeals Officers and how to prevent and cure those mistakes in future cases.
    • How to Challenge the Underlying Tax in CDP Cases (1 hour)
      Steve Klitzner discusses the authority under Code § 6330 for challenging a tax assessment through the CDP channel. We examine recent Tax Court decisions that explain when a taxpayer can and cannot raise such a challenge, as well as the Tax Court’s jurisdiction to review an IRS determination in this regard.
    • Tax Solutions Workshop – Specific Case Analysis Countering National, Local, and Transportation Standards (1 hour)
      Dan Pilla will moderate discussion with Q&A of all the issues and topics discussed during the day, with focus on a specific, actual case involving complex CDP and Tax Court appeals
    • Countering National, Local and Transportation Expense Standards  (2 hours)
      Dan Pilla examines the statutory and regulatory guidelines for the IRS’s National, Local and Transportation expense standards used in all collection cases, including Offers in Compromise. In addition, Pilla uses the Internal Revenue Manual (IRM) to illustrate what expenses are allowable or not.
    • Meeting the Burden of Proof in CDP Cases (1 hour)
      MacKenzie Hesselroth examines exactly how to the meet the taxpayer’s burden of proof in collection negotiations. We analyze IRS Forms 433-A and B, and Form 433-A (OIC). We explain which form is used, and when. We address IRM provisions on what must be proved for a taxpayer to get credit for personal living expenses and necessary business expenses in determining one’s ability to pay in the context of collection negotiations.
    • Recovering Fees and Costs of Litigation (2 hours ethics)
      Scott MacPherson addresses the ethical standards at play in requesting and recovering fees and costs of litigation when prevailing against the IRS. We examine the tax code and regulations together with the Tax Court Rules that govern this issue.
    • Figuring Reasonable Collection Potential in OIC Cases  (1 hour)
      Pilla uses information learned in the conference’s earlier sessions to demonstrate exactly how to calculate the amount of an Offer in Compromise, using IRM provisions and settled principles as set forth by the Tax Court.
    • Tax Solutions Workshop Bring Your Questions / Cases
      Group discussion of problems, questions, and strategies based upon all earlier presentations. We will present and discuss hypothetical cases involving various aspects of IRS problems resolution.

      Total credit hours- TBD, applying for 14 hours , including 1-2 hours ethics credit

MISSED Prior Conferences ??

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Pilla Tax Academy


Taxpayers Defense Conferences

Each year since 1993, Tax Freedom Institute founder and Executive Director, Daniel J. Pilla has presented the nation’s leading seminar for tax professionals, the Taxpayers Defense Conference. Designed specifically for tax pros in the business of helping taxpayers solve IRS audit, appeal and collection problems, Dan reveals the latest on exactly what to expect from the IRS and exactly how you can best help your clients weather the latest storm. To serve your clients in the best possible way, you need to know how to protect and defend your clients. That’s where the Taxpayers Defense Conference comes in.

Each year, Dan Pilla personally prepares the presentation topics for the Defense Conference. His topics always include the latest trends in IRS enforcement actions, court decisions, tax legislation and clients’ needs.



The Taxpayers Defense Conference is so unique and powerful in its ability to help you help your clients, it’s no wonder that more than 97% of the tax pros who’ve attended our seminar in the past say they would come back again.    In fact, many tax pros have attended this conference for more than 20 years in a row. How many seminars can you say that about? 

What Others Say About These Conferences

“The Taxpayer Defense Conference is what I wait for all year.  If you’ve been to one, you know what I’m talking about—THE BEST TAXPAYER DEFENSE CONFERENCE IN THE WORLD!  I know that most of you have attended many hours of continuing professional education in your career.  And I would bet the word that best describes the majority of CPE you’ve attended is . . . BORING.  The TFI Defense Conference is definitely NOT boring.  It’s not a bunch of stuffy egghead law professors and sleepy accountants droning on about esoteric crap that might affect less than 1% of your clients.  The Taxpayers’ Conference is a hands on participation event that teaches you the best and most effective methods for solving IRS issues we deal with every day. ”  Paul R. Tom – Attorney

“The Taxpayers Defense Conference exceeded my expectations as far as useful and informative information and outlines. The information will substantially assist me in my dealings with the IRS on behalf of my clients.”     Jim C. – Attorney

“If you’ve not attended, you’re missing the best opportunity you have to network with the best in the country. As far as I’m concerned, it’s a must.   Leo S. – CPA

“Bring your toughest IRS problem cases to the Taxpayer Defense Conference to discuss with Dan Pilla and the attendees.  You will have all of your questions answered.”    Steve Klitzner – Attorney

Dan Pilla was the presenter for a webinar I signed up for. He was by far one of the most informative and influential speakers I have ever heard from all the webinars I have taken. Not only did he give us quality advice on ways to execute tax resolutions, but he also had great insight on the tax laws and changes and how they could affect clients. He is a highly knowledgeable man and a great teacher! ”   Lubna J. Channo _CPA, CTS, CTP, CTC, CTRS, Macc_

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