Gain a better understanding of how to substantially reduce IRS tax penalties.
There are dozens of different penalties the IRS can assert against taxpayers. The defenses to such penalties are just as varied and often ill-defined in current guidance. Practitioners are often unaware of exactly how and when to challenge various IRS penalties. This topic will help tax practitioners understand the mechanics of various penalties and how best to defend taxpayers against IRS penalties. The material explains what defenses are applicable to certain penalties, how and when to assert such defenses, and methods for negotiating a reduction in penalties at various procedural stages. IRS penalty reduction/abatement has been decreasing steadily for the past decade - practitioners must therefore execute defenses to IRS penalties with precision to be successful. This material is critical for practitioners who represent taxpayers at all stages of tax controversy, from the initial examination stages all the way through final adjudication.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Overview of IRS Penalties
- Purpose of IRS Penalties
- Survey of Types of Penalties and Location in IRC
Defenses Against IRS Penalties
- Improper Imposition, Procedural (Managerial Approval Under 6751)
- Reasonable Basis
- Substantial Authority
- Reasonable Cause
Types of Penalties
- Accuracy Related
- Failure to File
- Failure to Pay
- Fraud Penalty
- Reportable Transaction Penalty
Contesting Penalties
- IRS Approach to Penalty Reduction/Abatement
- Relief During Exam
- Relief in IRS Appeals
- Relief After IRS Appeals
- Administrative Law Challenge
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on September 23, 2024.
Call 1-866-352-9540 for further credit information.
- AIPB 1.5
- This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
- AK CLE 1.5
- Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
- AL CLE 1.5
- This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.5 hours credit.
- AR CLE 1.5
- This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
- Arizona CLE 1.5
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.5
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
- CT CLE 1.5
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
- GA CLE 1.5
- This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.5 CLE hours.
- HI CLE 1.5
- This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
- IL CLE 1.5
- This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
- IN CLE 1.5
- This program has been approved by the Indiana Commission on Continuing Legal Education. Participating attorneys are eligible to receive up to 1.5 hours of Distance Education credit.
- MO CLE 1.8
- This course qualifies for self-study CLE credit in Missouri.
- MS CLE 1.5
- This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.5 credit hours.
- ND CLE 1.5
- North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.5 hours of CLE credit.
- NH MCLE 1.5
- NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 89 Minutes.
- NJ CLE 1.8
- This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.8 hours of total CLE credit.
- NM CLE 1.5
- This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.5 hours of credit.
- NV CLE 1.5
- This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
- NY CLE 1.5 including Areas of Professional Practice 1.5
- This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 1.5 credit hours in the area(s) of Areas of Professional Practice for 1.50 hours. Each hour may be counted only as satisfying one category of credit. Duplicate credit for the same hour of instruction is not permitted. This course qualifies for both established and newly admitted attorneys. Lorman Education- Noggin Guru, Inc. has a financial hardship guideline. Please contact customer service at 1.866.352.9539 for instructions on how to apply.
- OH CLE 1.5
- This course has been approved by the Ohio Supreme Court Commission on Continuing Legal Education for 1.5 CLE credit hours. Please note: No more than twelve (12) hours of self-study CLE credit for any biennial reporting period may be earned by an Attorney or Judge under Regulation 409.2. To fulfill CLE requirements for self-study, web-based programs, you must complete 100% of the polling questions during the program. Your hours will be filed electronically within thirty (30) business days by Lorman Education Services provided you fulfilled 100% attendance and polling questions answered.
- PA CLE 1.5
- This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
- RI CLE 1.5
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
- TN CLE 1.48
- This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.48 hours of credit.
- VT CLE 1.5
- This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
- WI CLE 1.5
- This program qualifies for 1.5 hour(s) of ondemand CLE through the WI Board of Bar Examiners.
- WV MCLE 1.8
- This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
MP3 Download
- AK CLE 1.5
- Arizona CLE 1.5
- CA MCLE 1.5
- CT CLE 1.5
- HI CLE 1.5
- MO CLE 1.8
- NJ CLE 1.8
- NM CLE 1.5
- NY CLE 1.5 including Areas of Professional Practice 1.5
- VT CLE 1.5
- WV MCLE 1.8
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Logan Chaney Abernathy
Dentons Sirote
- Associate in Dentons Sirote’s Huntsville, Alabama office and is a member of the tax practice group
- Practice focuses on tax controversy, tax litigation, and government investigations
- Has clerked for the United States Attorney’s Office for the Western District of Tennessee, the Jackson County (Alabama) District Attorney’s Office, and United States District Judge L. Scott Coogler in Tuscaloosa, Alabama
- While attending law school, she served as Editor in Chief of the Law and Psychology Review and as the Chief Operating Officer for Raise the Bar, a student-run mentoring program affiliated with the University of Alabama School of Law and Eastwood Middle School
- J.D. degree, magna cum laude, University of Alabama School of Law; B.A. degree in criminology, summa cum laude, Mississippi State University
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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