Find out how to prevent IRS penalties and what opportunities exist if you are penalized.
The Internal Revenue Code has more than140 penalty provisions and the Internal Revenue Service has dramatically increased the number of penalties it imposes on taxpayers. From 2005 to 2010, the Internal Revenue Service's assessment of accuracy-related penalties against individuals increased by more than 800%. Taxpayers who are hit with penalties have different avenues for relief, but often are unaware that relief is available. This topic helps taxpayers and tax practitioners understand the different types of penalties that the IRS may assert, how the IRS determines whether to assert penalties, and what taxpayers can do to minimize their risk of being hit with penalties. Taxpayers and practitioners are also given tools to defend against the assertion of penalties by the IRS, both at the Exam level and at IRS Appeals. Knowing how the IRS views and assesses penalties before the return is even filed is critical to succeeding in defending against penalties if that return is selected for audit.
Agenda
Faculty
Michelle Abroms Levin
Dentons Sirote
- Shareholder in Dentons Sirote’s Huntsville, Alabama office, where she is a member of the tax practice group
- Represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, and federal district court
- Experience includes a wide range of complex tax issues
- Counsels clients in tax and business planning
- Works with clients to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels
- Prior to joining Dentons Sirote (formerly Sirote & Permutt, PC), she worked as a trial attorney at the Tax Division of the Department of Justice, where she represented the United States in federal district court
Gregory P. Rhodes
Dentons Sirote
- Shareholder in the Birmingham office of Sirote & Permutt, PC
- Practice emphasizes tax controversies, tax litigation and tax planning
- Wrote several publications related to tax controversy and tax planning, including Navigating the Defenses to Valuation Penalties in Charitable Deduction Cases published in the Journal of Taxation’s December 2014 edition; Mr. Rhodes’ articles on developments in the world of tax controversy and IRS penalties can be found on Sirote’s tax controversy blog: http://www.sirote.com/blog/tax-controversy/
- J.D. degree, University of Mississippi; LL.M. degree in taxation, New York University
- Can be contacted at 205-930-5445 or [email protected]
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