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Mastering IRS Representation: Reopening an IRS Assessment

MASTERING IRS REPRESENTATION: REOPENING AN IRS ASSESSMENT

Cost Free
Presentation Length 1.0 hour

Recorded DateNovember 10, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

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 webinar 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 webinar will explain each option and when practitioners should consider utilizing each of them.

Learning Objectives:


  • Define the options available to practitioners for reopening assessed tax liabilities

  • Identify the specific circumstances and criteria under which each reopening option should be considered and determine the most appropriate approach based on the client's situation

  • List the step-by-step procedures and best practices for effectively utilizing each reopening option

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Eric is a partner in Green & Sklarz LLC, a boutique tax firm with Connecticut and New York offices. The focus of Attorney Eric L. Green's practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service, and state Departments of Revenue Services. His practice also handles probate matters and estate planning for individuals and business owners, and tax planning for closely-held businesses. He is a frequent lecturer on tax topics for CCH, the NAEA, the NATP, the ABA Tax Section, and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He is the author of The Accountant's Guide to IRS Collection (available www.tgpublish.com), and he is a columnist for CCH's Journal of Practice & Procedure. He is also the founder of The New England IRS Representation Conference. Mr. Green is a contributing author for Advocating for Low-Income Taxpayers: A Clinical Studies Casebook, 3rd Edition, and has also been quoted in The Wall Street Journal, USA Today, Consumer Reports, The Wall Street Journal's Market Watch, TheStreet.com, and CreditCard.com. Before practicing law Attorney Green served as a senior tax consultant for KPMG and Deloitte & Touche. Attorney Green was the 2010 Nolan Fellow of the American Bar Association and has served as Chair of the American Bar Association's Closely Held Businesses Tax Committee. Attorney Green is the current Chair of the Executive Committee of the Connecticut Bar Association's Tax Section. Eric is a Fellow of the American College of Tax Counsel ("ACTC") and a Connecticut, Massachusetts, New York, and American Bar Association member. He is admitted to practice in Massachusetts, New York, and Connecticut Superior Courts, as well as the United States Tax Court, the Federal Court of Claims, and the Federal District Court for Connecticut. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honor graduate from New England School of Law. He earned a Masters of Laws in Taxation (LL.M.) from Boston University School of Law.


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Taxrepnetwork
The Tax Rep LLC is an online member-driven organization whose mission is to enhance all of its members IRS representation practices by sharing experiences, representation techniques and marketing strategies with each other.