COURSE DESCRIPTION
This program will provide you with a practical guide to defending closely held businesses and owners against IRS audits and collection activity. The program will discuss counseling clients about what to expect in the process and preparing their documentation for review. It will also cover assessing their potential liability and preparing strategies accordingly. The differences between income and employment tax issues will also be covered. This program will provide you with real world guide to defending against IRS audit and collection activity of closely held companies.
Day 1
- Ascertaining the IRS’s goals and determining a reasonable range of settlements
- Types of settlements and IRS settlement standards
- Appeals process and rates of success at each level
- Negotiating an audit settlement in anticipation of collections
- Collections process, defenses, and forms of penalty
Day 2
- Counseling clients about the scope and nature of IRS collection activity
- IRS use of asset freezes – cash and liquid assets
- Liens and levies – and how to obtain releases
- Obtaining injunctive relief from collection activity
- Interrelationship of bankruptcy law and collection activity
Speakers:
Stephen J. Turanchik is an attorney in the Los Angeles office of Paul Hastings, LLP, where his practice focuses on tax litigation at the state and federal levels as well as tax controversy work at the administrative levels. Before entering private practice, he is previously litigated for six years for the U.S. Department of Justice, Tax Division, where he litigated cases in federal, bankruptcy, state and probate court.