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.What You'll Learn: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