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Resolving Payroll Tax Issues (Presented by Tax Rep)

Master IRS payroll tax assessment procedures, Trust Fund Recovery Penalty defenses, and resolution strategies for representing responsible persons facing personal liability.

2025-03-26 10:00:00

Program Details

2025-03-26 10:00:00

2025-03-26 10:00:00

2h CLE Credits

Program Details

2025-03-26 10:00:00

Program Details

2025-03-26 10:00:00

Over 1,000+ webinars

2025-03-26 10:00:00

Course Overview

Resolving Payroll Tax Debts and Personal Liability

2025-03-26 10:00:00

Participants will learn how IRS assesses unpaid payroll taxes against businesses and responsible individuals, including Trust Fund Recovery Penalty procedures and strategic resolution approaches. Gain practical skills for defending clients and negotiating favorable outcomes.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Personal Liability
Responsible persons face 100% trust fund penalty with joint and several liability.
02
4180 Interview
Revenue Officers use Form 4180 to determine who is responsible for unpaid taxes.
03
Protest Rights
Recipients of Letter 1153 have 60 days to file a protest or sign waiver.
04
Evidence Building
Gather bank signature cards, canceled checks, affidavits, and FOIA administrative files.
05
Voluntary Payments
Individual payments with written direction can be applied directly to trust fund liability.
06
Third-Party Risk
Employers remain liable for taxes even if payroll companies embezzle the funds.

Program schedule

clock 10:00 am - 10:30 am EST

IRS Assessment of Companies and Responsible Individuals

This session examines how the IRS assesses and collects unpaid payroll taxes from businesses, including the enforcement landscape and the Federal Tax Deposit Alert System. Participants will learn why payroll taxes represent the leading cause of small business tax trouble and understand the risks associated with third-party payroll companies.

Eric L. GreenEric L. Green
clock 10:30 am - 11:00 am EST

Identifying Personally Liable Parties for Payroll Taxes

This session covers who may be deemed personally responsible for unpaid payroll taxes under IRC § 6672, from proprietors and partners to bookkeepers and lenders. Attendees will learn the functional test for responsibility, indicators the IRS examines, and how joint and several liability affects multiple responsible persons.

Eric L. GreenEric L. Green
clock 11:00 am - 11:10 am EST

Break

A short break to refresh before continuing with the program.

Eric L. GreenEric L. Green
clock 11:10 am - 12:10 pm EST

Assessment Procedures and Resolution Strategies Under IRC § 6672

This comprehensive session walks through the Trust Fund Recovery Penalty assessment process, including the 4180 interview, Letter 1153, and filing effective protests. Participants will explore strategic options including voluntary payment direction, doubt as to liability offers, and when to advise clients to close their business.

Eric L. GreenEric L. Green
Eric L. Green

Eric L. Green

Green & Sklarz, LLC

Eric L. Green

Eric L. Green

Green & Sklarz, LLC

Eric L. Green is the managing partner and co-founder of Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York, and the founder of Tax Rep LLC and the Tax Rep Network — the country’s leading training and coaching program for tax representation practitioners. His practice focuses on civil and criminal taxpayer representation before the IRS, the DOJ Tax Division, and state departments of revenue. Eric is a nationally renowned tax expert who has lectured to more than 70,000 practitioners, is a Fellow of the American College of Tax Counsel, a past Chair of the Connecticut Bar Association’s Tax Section, and the host of the weekly Tax Rep Network podcast. He holds a B.B.A. in Accounting from Hofstra University, a J.D. (Honors) from New England School of Law, and an LL.M. in Taxation from Boston University School of Law. Prior to practicing law, he was a senior tax consultant at KPMG and Deloitte & Touche.

Education & Credentials

Eric holds a Bachelor of Business Administration in Accounting with a minor in International Business from Hofstra University, a Juris Doctor with honors from New England School of Law, and a Master of Laws in Taxation from Boston University School of Law. He is admitted to practice in New York, Connecticut, and Massachusetts and is a member of the U.S. Tax Court Bar. He is a Fellow of the American College of Tax Counsel — a peer-nominated honor reserved for those at the top of the tax law profession — and holds the Certified Tax Representation Consultant (CTRC) designation through the program he co-developed with Becker Professional Education.

Recognition & Leadership

Eric has been recognized by Connecticut Super Lawyers in the field of Tax and was the 2010 Nolan Fellow of the American Bar Association. He is a Fellow of the American College of Tax Counsel and a past Chair of the Connecticut Bar Association’s Tax Section and the ABA’s Closely Held Businesses Tax Committee. His Tax Rep Network has trained over 500,000 tax, accounting, and legal professionals annually and is the profession’s most widely used IRS representation training platform. He has been quoted in the Wall Street Journal, USA Today, CNN, and Consumer Reports Financial News.

Professional Involvement

Eric is the founder and principal instructor of Tax Rep LLC and the Tax Rep Network, through which he delivers the weekly Tax Rep Network podcast, webinars, live conferences, and the Annual IRS Representation Conference. He is a frequent lecturer for the ABA Tax Section, the AICPA, the NATP, the NAEA, and numerous state CPA and enrolled agent societies. He co-developed the Certified Tax Representation Consultant (CTRC) certification with Becker Professional Education and previously served as adjunct faculty at the University of Connecticut School of Law, where he taught taxpayer representation in the low-income taxpayer clinic. He is also a co-author of a casebook for clinical programs assisting low-income taxpayers with federal income tax controversies.

Experience

Before founding Green & Sklarz LLC, Eric served as a senior tax consultant at KPMG and Deloitte & Touche — experience that gives him an unusually grounded understanding of how large-scale accounting practice and IRS representation intersect. At Green & Sklarz, he has built a national reputation for negotiating favorable settlements in thousands of civil cases and for convincing government agents to resolve criminal investigations civilly. He founded Tax Rep LLC and the Tax Rep Network to extend that expertise — and his practical teaching approach — to practitioners across the country who want to build or grow their own tax representation practices. His career represents the rare combination of elite technical expertise, prolific national education, and entrepreneurial platform-building that has made him one of the most recognizable names in American tax representation.
Eric L. Green

Eric L. Green

Green & Sklarz, LLC

Eric L. Green is the managing partner and co-founder of Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York, and the founder of Tax Rep LLC and the Tax Rep Network — the country’s leading training and coaching program for tax representation practitioners. His practice focuses on civil and criminal taxpayer representation before the IRS, the DOJ Tax Division, and state departments of revenue. Eric is a nationally renowned tax expert who has lectured to more than 70,000 practitioners, is a Fellow of the American College of Tax Counsel, a past Chair of the Connecticut Bar Association’s Tax Section, and the host of the weekly Tax Rep Network podcast. He holds a B.B.A. in Accounting from Hofstra University, a J.D. (Honors) from New England School of Law, and an LL.M. in Taxation from Boston University School of Law. Prior to practicing law, he was a senior tax consultant at KPMG and Deloitte & Touche.

Education & Credentials

Eric holds a Bachelor of Business Administration in Accounting with a minor in International Business from Hofstra University, a Juris Doctor with honors from New England School of Law, and a Master of Laws in Taxation from Boston University School of Law. He is admitted to practice in New York, Connecticut, and Massachusetts and is a member of the U.S. Tax Court Bar. He is a Fellow of the American College of Tax Counsel — a peer-nominated honor reserved for those at the top of the tax law profession — and holds the Certified Tax Representation Consultant (CTRC) designation through the program he co-developed with Becker Professional Education.

Recognition & Leadership

Eric has been recognized by Connecticut Super Lawyers in the field of Tax and was the 2010 Nolan Fellow of the American Bar Association. He is a Fellow of the American College of Tax Counsel and a past Chair of the Connecticut Bar Association’s Tax Section and the ABA’s Closely Held Businesses Tax Committee. His Tax Rep Network has trained over 500,000 tax, accounting, and legal professionals annually and is the profession’s most widely used IRS representation training platform. He has been quoted in the Wall Street Journal, USA Today, CNN, and Consumer Reports Financial News.

Professional Involvement

Eric is the founder and principal instructor of Tax Rep LLC and the Tax Rep Network, through which he delivers the weekly Tax Rep Network podcast, webinars, live conferences, and the Annual IRS Representation Conference. He is a frequent lecturer for the ABA Tax Section, the AICPA, the NATP, the NAEA, and numerous state CPA and enrolled agent societies. He co-developed the Certified Tax Representation Consultant (CTRC) certification with Becker Professional Education and previously served as adjunct faculty at the University of Connecticut School of Law, where he taught taxpayer representation in the low-income taxpayer clinic. He is also a co-author of a casebook for clinical programs assisting low-income taxpayers with federal income tax controversies.

Experience

Before founding Green & Sklarz LLC, Eric served as a senior tax consultant at KPMG and Deloitte & Touche — experience that gives him an unusually grounded understanding of how large-scale accounting practice and IRS representation intersect. At Green & Sklarz, he has built a national reputation for negotiating favorable settlements in thousands of civil cases and for convincing government agents to resolve criminal investigations civilly. He founded Tax Rep LLC and the Tax Rep Network to extend that expertise — and his practical teaching approach — to practitioners across the country who want to build or grow their own tax representation practices. His career represents the rare combination of elite technical expertise, prolific national education, and entrepreneurial platform-building that has made him one of the most recognizable names in American tax representation.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

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MCLE Credits

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Pending
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Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
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Approved
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Kentucky
Pending
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Pending
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Maryland
No Required
Massachusetts
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Michigan
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Minnesota
Approved
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Approved
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
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Approved
Ohio
Approved
Oklahoma
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Oregon
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Pennsylvania
Approved
Rhode Island
Pending
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No Required
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Pending
Texas
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Approved
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Not Eligible
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Approved
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Pending
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Approved
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Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs