Introduction

Tax penalties and disputes can be financially and legally damaging for individuals and businesses. Understanding how to mitigate penalties, file appeals, and negotiate settlements is critical for tax professionals, corporate finance teams, and legal advisors.

This 5-day intensive course is designed for CPAs, tax attorneys, corporate tax managers, and financial consultants who need to navigate tax penalty disputes, IRS appeals, and penalty abatement strategies. Participants will gain hands-on experience in penalty negotiations, administrative appeals, and IRS dispute resolution tactics.

Course Objectives

By the end of this course, participants will be able to:

• Understand common IRS tax penalties and how they are assessed.
• Develop strategies to reduce or eliminate penalties through abatement requests.
• Navigate IRS appeals, Taxpayer Advocate assistance, and settlement options.
• Handle interest calculations, installment agreements, and penalty disputes.
• Manage compliance risks to prevent future tax penalties.

Who Should Attend?

This course is ideal for professionals handling tax penalties, disputes, and appeals, including:

• Tax attorneys and legal advisors specializing in IRS dispute resolution.
• CPAs and Enrolled Agents (EAs) representing clients in penalty negotiations.
• Corporate tax managers and CFOs managing business tax penalties.
• Forensic accountants and financial consultants investigating tax compliance issues.
• Small business owners and individuals facing IRS penalties.

Course Outline

Day 1: Understanding Tax Penalties and How to Challenge Them

• Common tax penalties: Late filing, underpayment, accuracy-related, and fraud penalties.
• Interest and penalty calculations: How the IRS determines additional charges.
• IRS penalty classifications: Civil vs. criminal tax penalties.
• Preventing tax penalties through compliance best practices.
• How taxpayers can challenge penalties: Rights and options.

Workshop: Calculating IRS penalties and interest for late tax payments.

Day 2: Penalty Abatement and Relief Strategies

• Reasonable cause vs. first-time penalty abatement (FTA).
• Applying for penalty relief under IRS guidelines.
• Submitting Form 843 (Claim for Refund and Request for Abatement).
• IRS discretion in penalty relief: How to make a strong case.
• How tax professionals can help clients avoid unnecessary penalties.

Case Study: Drafting a penalty abatement request for a taxpayer with reasonable cause.

Day 3: IRS Appeals and Administrative Review Process

• Understanding the IRS Independent Office of Appeals.
• When to file an appeal and how to prepare a strong case.
• IRS administrative review process and procedural rules.
• Alternative dispute resolution (ADR) for penalty disputes.
• Best practices for negotiating with IRS appeals officers.

Scenario Analysis: Preparing a tax penalty appeal for a corporate client.

Day 4: Settlement Strategies and Taxpayer Advocacy

• Offer in Compromise (OIC) and how to negotiate tax debt settlements.
• IRS installment agreements and payment plans.
• Taxpayer Advocate Service (TAS) and when to seek intervention.
• Audit reconsideration: When and how to request a review.
• Litigating tax penalties: When court action is necessary.

Mock Negotiation: Settling a tax penalty dispute through an IRS appeals conference.

Day 5: Preventing Future Tax Penalties & Compliance Strategies

• Best practices for proactive tax compliance and risk management.
• Tax planning strategies to reduce penalty risks.
• IRS enforcement trends and new penalty regulations.
• Final Capstone: Participants develop a tax penalty resolution strategy for a high-risk client.

Conclusion & Certification

Participants who complete the course and pass the final assessment will receive a Certification in Tax Penalty Resolution & Appeals, demonstrating expertise in IRS dispute resolution, penalty abatement, and tax appeals procedures.

Program Benefits

• Expert-Led Training – Learn from tax attorneys, IRS dispute specialists, and forensic accountants.
• Hands-On Learning – Engage in mock appeals, case studies, and penalty abatement exercises.
• Strategic Dispute Resolution – Strengthen negotiation tactics and settlement strategies.
• Legal & Compliance Focus – Understand IRS regulations and penalty relief procedures.
• Career Growth – Gain an edge in corporate tax, forensic accounting, and IRS representation.

Career Opportunities After Certification

• Tax Controversy Specialist – Managing IRS penalty disputes and appeals.
• Corporate Tax Risk Manager – Preventing business tax compliance issues.
• IRS Audit Defense Consultant – Assisting clients in penalty abatement and settlements.
• Tax Litigation Attorney – Representing clients in tax disputes and court appeals.
• Forensic Tax Accountant – Investigating penalty risks and compliance violations.