The IRS asserts millions of dollars in tax penalties against taxpayers each year.  This webinar will teach you how to represent your client and seek abatement and removal of IRS penalties.  You will learn about Reasonable Cause exceptions to penalties, the First Time Penalty Abatement procedures, various methods to request penalty abatement (e.g. in exam, appeals, post-appeals, Collection Due Process), and how to litigate penalty abatement requests when you are unsuccessful in the examination , administrative, or appellate stage.  We will also discuss the various types of penalties that the IRS may assert against your client.

Webinar Objectives

This webinar will provide insight and tools to assist you and your clients understand what penalties may be asserted if certain actions are taken, or not taken.  You will learn how to dispute penalties at the various stages of a penalty lifecycle; e.g. examination stage, appellate stage, collection stage, and refund stage.  Lastly, you will learn about the ability to dispute penalties administratively and through formal litigation in Tax Court and District Court.


Webinar Highlights
  • The various penalties the IRS could assert against a taxpayer, including penalties related to foreign assets.
  • Contesting Penalties in Examination
  • Contesting Penalties in Appeals
  • Contesting Penalties in Collection Due Process
  • Contesting Penalties in Tax Court
  • Contesting Penalties in District Court
  • Automatic vs Discretionary Penalties
  • Reasonable Cause exception to Penalties

Who Should Attend?

Accountants, tax preparers, CFOs, financial compliance professionals, and lawyers


Client Testimonial (MarcT)

This was my second tax law related seminar (one on civil tax fraud and the other on penalty abatement requests) presented by attorney Adam Fayne. He explains the complex clearly (e.g., the elements of civil tax fraud, defenses, and the IRS’s burden of proof), he understands what he is talking about (e.g., frequently providing numerous real-world examples from his own tax law practice), and he has depth of knowledge of tax law (which is rare for such a vast topic). He does the little things that a seminar attendee would appreciate. His slides seen throughout the seminar are a helpful and concise resource for later reference. Also, Mr. Fayne  took the time at the beginning to let us know about a recent US Tax Court decision decided days before the seminar that provides potential refund opportunities to taxpayers inappropriately assessed “Form 5471 penalties.” Similarly, he mentioned and cited on slides, when relevant, citations to the tax code, the  Internal Revenue Manual, and case law. I’d give both seminars I have attended my highest recommendation to experienced tax practitioners, as well as those new to that practice.