Notice of Deficiency? Now What?
Friday, September 22, 2023 | 1pm – 3pm Eastern | via Live Webinar
Your client received the request for supporting documentation and you dutifully submitted it by the deadline. Instead of a letter thanking you for being so diligent, instead arrives a dreaded Notice of Deficiency, telling your client they believe they owe money and giving you 90-days to file in United States Tax Court. Why? It’s almost as if a human being did not even look at what you sent…
This program will review the process for challenging the Notice of Deficiency, including the process from Tax Court on, and what to do if the Tax Court deadline is missed.
Learning Objectives:
-
Understand the process for challenging the Notice of Deficiency
-
Describe the process once a United States Tax Court petition is filed
-
Explain how to resolve the case with Appeals if it has not already been heard by Appeals
Due to the in-depth nature of this workshop, attendance is limited, so all attendee questions can be answered.
THIS PROGRAM IS PART OF THE 2023 TRN WORKSHOP SERIES!
Register for THIRTEEN of the 2023 TRN Workshop Series programs at once AND SAVE $$$ !
If you buy all the programs separately: Early Bird $887 (regular $1,117)
BUNDLE PRICE = $887 (for an additional $270 OFF regular!)
Learn More About Each Program of the 2023 Workshop Series
2 HOURS
This incredibly popular program is updated for 2023 and will cover those mistakes practitioners make during tax season that can cause the IRS to start enforcement action, either through an audit or collection. We will also cover the IRS priorities and what it is flagging for audit and enforcement. Join us for the program that will help you avoid the pitfalls that can cause you and your client extreme heartburn!
Learning Objectives:
- Understand the common mistakes made by tax preparers during tax season and how to avoid them
- Identify potential collection issues before there turns are filed
- Understand the strategies for resolving tax debts before they arise
2 HOURS
Those late-night commercials make it sound so easy, but how do you get rid of tax penalties? This program will cover first-time penalty abatement, abatement for reasonable cause, and what needs to be in your abatement letter to win every time.
Learning Objectives:
- Summarize the first-time abatement program and when it applies
- Describe reasonable cause for the avoidance of penalties
- Identify critical items in your abatement request or appeal
4 HOURS
Join us for this workshop where Tax Attorney and National Speaker Eric Green will walk you through the IRS Collections process and how to utilize the rules to resolve your client’s nightmare with regards to everything from tax liens and tax levies to collection appeals. Given the current economic uncertainty there has never been a better time to add this specialized and highly sought-after service to your current practice. With 15 million taxpayers in the collection division’s inventory, and another 10 million non-filers, and with the IRS armed with $80 billion of new funding for enforcement, the need for trained representatives to help taxpayers is going to explode.
This special workshop will include the following:
- The IRS Collection Process
- The IRS Notices
- Tax Liens
- Tax Levies
- Installment Agreements
- Uncollectible Status
- Offers-in-Compromise
- Collection Appeals
- Tools for Managing an IRS Representation Practice
- Marketing: How to Find Clients
The workshop will include detailed case studies, including all of the necessary forms and letters. Attendees will receive checklists, sample letters, and tons of exhibits that they can use right in their own practice. Eric will also review marketing techniques to help attendees find clients and add an extra $100,000 to their bottom line!
Learning Objectives:
- Explain the IRS Collection process
- Identify opportunities to help taxpayers resolve their outstanding tax debts
- Describe how tax liens work and options for removing them
- Explain the mechanics of a tax levy
- Identify what is required for tax compliance
- Explain the options for resolving an outstanding tax debt
- Describe how to resolve tax issues with the Collection Appeals function
4 HOURS
Join us for this very special workshop where Tax Attorney and National Speaker Eric Green will walk you through how to file an Offer-in-Compromise that gets accepted. Given the current economic uncertainty there has never been a better time to add this specialized and highly sought-after service to your current practice. With 15 million taxpayers in the collection division’s inventory, and another 7 million non-filers BEFORE the COVID-19 pandemic began, the need for trained representatives to help taxpayers is going to explode.
This special workshop will include the following:
- A review of the Offer-in-Compromise program,
- An in-depth analysis of the 4 different types of Offers and when to use each,
- How Reasonable Collection Potential is calculated by the IRS,
- How to find clients,
- Strategies you can employ to help your taxpayer resolve their issue quickly and efficiently.
The workshop will include detailed case studies, including all of the necessary forms and letters. Attendees will receive checklists, sample letters, and tons of exhibits that they can use right in their own practice. Eric will also review marketing techniques to help attendees find clients and add an extra $100,000 to their bottom line!
Learning Objectives:
- Explain the Offer-in-Compromise process and how the IRS program works
- Identify opportunities to help taxpayers make themselves a better Offer-in-Compromise candidate
- Describe how the IRS calculated reasonable collection potential
- Explain the requirements to qualify for an Offer-in-Compromise
- Identify what is required to maintain tax compliance
- Describe how to prepare an Appeal of a denied Offer
2 HOURS
This program will explain the mechanics of the IRS tax levy. In particular, the program will cover the mechanics of tax levies, how to avoid issues with levies, and how to get rid of any levies when they are issued.
Learning Objectives:
- Recognize the differences between tax liens and tax levies
- Identify when the IRS utilizes a levy
- Define the options for having a tax levy removed
2 HOURS
Ever dealt with an auditor that you begin to realize immediately must be named Lucifer? The point of an audit, according to the IRS itself, is to check on how the taxpayer is doing in respect to their returns and reporting and use this time as an educational opportunity. Yet sometimes there are examiners who do not seem to understand this and have decided it’s a time to torture you and your client. Trust us, you do not need to take their abuse! This program will review the options for what to do when the IRS employee seems to be out of control, including the taxpayer bill of rights, the role of the taxpayer advocate and congressional constituent services.
Learning Objectives:
- Describe the examination procedures auditors are supposed to follow
- Explain the taxpayer bill of rights
- Identify opportunities to get assistance when the examination process is not working properly
2 HOURS
Whether by examination or through the collection process, there are times your client will need to seek an independent review of their case to get it resolved. This program will cover how the Independent office of Appeals operates, how clients can take their cases there to be considered, and how best to line up your client’s case to give them the best opportunity to resolve the tax debt.
Learning Objectives:
- Understand the various forms of collection appeals
- Explain the role of tax compliance in the appeal
- Identify how cases can get to appeals
- Describe when each type of appeal is appropriate for your taxpayer’s case
2 HOURS
When business suffers taxpayers begin cheating. So what can you do if your client knows about tax crimes being committed? They can strike a blow for justice, the American tax system, and get paid doing it. Nothing more American than that! Attorney Eric Green will review the IRS Whistleblower program, discuss how your client can bring a claim that stands the best chance of receiving an award, and how the system ACTUALLY works!
Learning Objectives:
- Explain how the IRS whistleblower program works
- Describe how whistleblower claims are filed
- Explain how the whistleblower awards are calculated and challenged
2 HOURS
Your client received the request for supporting documentation and you dutifully submitted it by the deadline. Instead of a letter thanking you for being so diligent, instead arrives a dreaded Notice of Deficiency, telling your client they believe they owe money and giving you 90-days to file in United States Tax Court. Why? It’s almost as if a human being did not even look at what you sent…
This program will review the process for challenging the Notice of Deficiency, including the process from Tax Court on, and what to do if the Tax Court deadline is missed.
Learning Objectives:
- Understand the process for challenging the Notice of Deficiency
- Describe the process once a United States Tax Court petition is filed
- Explain how to resolve the case with Appeals if it has not already been heard by Appeals
2 HOURS
Our will update you on where the IRS stands on voluntary disclosure for domestic and foreign issues and how best to use the program to save your client from their past misdeeds. We will also cover topics with the IRS disclosure form 14457 and issues you need to address with the client before filing, and what to do about the state tax returns impacted by the same conduct!
Learning Objectives:
- Understand the IRS Voluntary Disclosure Program
- Identify Issues that need to be addressed with the taxpayer prior to disclosure
- Explain the impact and process for disclosing and correcting the state tax filings
3 HOURS
So you may have handled an IRS audit, or maybe just a state sales tax audit. This workshop will walk attendees through how sales tax audits are done and do so by comparing and contrasting these techniques with IRS examination techniques for both income tax and Federal Excise Tax. We will review the techniques used by the various states and how practitioners can help protect their client from the overzealous state auditor. The program will compare the state audit techniques used by the IRS auditors so practitioners get a well-rounded review and comparison between the two approaches and what they need to know to help their client handle each type of audit.
This special workshop will include the following:
- A review both federal and state audit techniques,
- A review of the different approaches taken by states than that of the IRS
- A detailed discussion of preparing for the audit
- Dealing with the auditor, the request for interview and the Quickbooks file
- What to do if the client’s records are less than stellar
- Issues surrounding cash intensive businesses
- The income tax impact of the bad sales tax audit
- Preparing and handling the appeal
The workshop will include detailed exhibits, forms and reviews of actual cases to illustrate the good and bad that can go on, and what to do when the audit starts to go off the rails. Eric will also review marketing techniques to help attendees find clients and add an extra $100,000 to their bottom line!
Learning Objectives:
- Explain both the IRS and state audit selection process
- Identify similarities and differences in the approach to testing for federal and state audits
- Describe how the audit process is different from the state testing techniques and the federal testing techniques
- Explain the issues surrounding cash intensive businesses
- Describe how the approach to Appeals is different with various states vs the IRS
2 HOURS
With the challenges of staffing and the pandemic, the IRS has increased its use of automation, including the automated under reporter and automated substitute for returns. Many of these proposed assessments either go unchallenged by taxpayers or, when documents are submitted, they are ignored by the IRS, leading to bad assessments and enforcement against taxpayers. This program will explain the opportunities for practitioners to reopen assessed tax liabilities, including audit reconsideration, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing. The program will explain each option and when practitioners should consider utilizing each of them.
Learning Objectives:
- Understand how to request audit reconsideration
- Identify when is it possible to use an amended return to reopen a bad assessment
- Explain how Doubt-as-to-Liability Offers work
- Understand how to utilize a CDP hearing to force a reconsideration of a tax liability
- Describe how to use refund requests to reopen a bad assessment
2 HOURS – ETHICS
During this year-end round-up of ethical issues we will cover the most common ethical issues and make sure you are up to date on what to do (and not do) next tax season. The issues raised in Circular 230 regarding conflicts of interest, client documentation and tax prep, preparer penalties and defense, and the role of OPR will all be reviewed with new cases being discussed. A fun way to make sure you are up to speed on your ethical responsibilities and nail those last credits before tax season 2024!
Learning Objectives:
- Understand the role of Circular 230 and its requirements
- Describe the rules around conflicts of interest and what practitioners can do to address them
- Identify ethical issues that arise during tax season and how best to handle them and document your file
- Explain the role of OPR
EDUCATION INFORMATION
Learning Objectives:
- Understand the process for challenging the Notice of Deficiency
- Describe the process once a United States Tax Court petition is filed
- Explain how to resolve the case with Appeals if it has not already been heard by Appeals
Prerequisites: None
Advanced Preparation: None
Program Level: Intermediate
Delivery Method: Group Internet Based
Field of Study: Tax
CPE: 2 hours
IRS CE: 2 hours
Green & Sklarz, LLC is the sponsoring organization for Tax Rep LLC’s CPE programming. Green & Sklarz, LLC is registered with the National Association of the State Boards of Accountancy (NASBA) as a sponsor of continuing education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org. Green & Sklarz, LLC’s NASBA sponsor number is 132892.

Program Number: 15UFN-T-00245-22-O
Title: Notice of Deficiency? Now What?
Cancellation Policy: If you find you cannot make the program after registering, please contact our office by either email (hello@taxrepllc.com or by phone (203-285-8545) and let us know you will be unable to make the program.
Concerns or Complaints: If you have suggestions or concerns about anything in the program or the materials, please direct them to Nicole Golino at ngolino@gs-lawfirm.com or by calling us at (203) 285-8545.
CPE Credits & Field of Study: Recommended 2 CPE Credit Hours in the Field of Taxation. In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour