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Challenging Assessed Taxes: Audit reconsiderations, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing (Presented by Tax Rep)

2025-09-18 15:00:00

2025-09-18 15:00:00

1 Credits

Master strategies to challenge incorrect IRS assessments through audit reconsideration, doubt-as-to-liability offers, CDP hearings, and refund claims.

2025-09-18 15:00:00

Master strategies to challenge incorrect IRS assessments through audit reconsideration, doubt-as-to-liability offers, CDP hearings, and refund claims.

2025-09-18 15:00:00

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1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

Course Overview

Reopening Bad IRS Tax Assessments

Participants will learn multiple strategies to challenge incorrect IRS assessments, from audit reconsideration to bankruptcy court options. These techniques address the growing problem of automated correspondence examinations.

Key topics that will be covered

What will you learn

Attorneys will learn multiple methods for reopening incorrect IRS assessments, including audit reconsideration, doubt-as-to-liability offers, CDP hearings, and refund claims.

What will you gain

Attorneys will gain practical strategies for challenging bad assessments caused by automation, correspondence examinations, substitute returns, and ignored taxpayer submissions.

Bad Assessments
Understand how automation, substitute returns, and ignored responses create incorrect assessments.
Audit Reconsideration
Submit new information with complete documentation packages to request IRS reconsideration.
Doubt-as-to-Liability
Use Form 656-L to stop collection immediately while challenging the underlying liability.
CDP Hearings
Challenge assessments through Collection Due Process when no prior opportunity existed.
Refund Claims
Pay the balance and file Form 843 to guarantee court access.
Bankruptcy Court
Challenge IRS proof of claim when taxpayers file for bankruptcy protection.

What will you learn

Attorneys will learn multiple methods for reopening incorrect IRS assessments, including audit reconsideration, doubt-as-to-liability offers, CDP hearings, and refund claims.

What will you gain

Attorneys will gain practical strategies for challenging bad assessments caused by automation, correspondence examinations, substitute returns, and ignored taxpayer submissions.

Agenda

Session 1

How to Request IRS Audit Reconsideration

Session 2

Using Amended Returns to Reopen Bad Assessments

Session 3

Understanding How Doubt-as-to-Liability Offers Work

Session 4

Utilizing CDP Hearings to Force Liability Reconsideration

Session 5

Using Refund Requests to Reopen Bad Assessments

clock 3:00 pm - 3:05 pm EST

How to Request IRS Audit Reconsideration

Eric L. Green

Green & Sklarz, LLC.

Learn the requirements and process for requesting audit reconsideration when challenging a bad IRS assessment. Discover what qualifies as new information and how to submit a complete documentation package using Publication 3598 and Form 12661.

Eric L. Green

Green & Sklarz, LLC.

clock 3:05 pm - 3:15 pm EST

Using Amended Returns to Reopen Bad Assessments

Eric L. Green

Green & Sklarz, LLC.

Understand how to correct substitute for returns by filing original returns and when amended returns can be used to challenge assessments. Explore the timing rules, refund limitations under Section 6511, and circumstances that prevent reopening such as court decisions or closing agreements.

Eric L. Green

Green & Sklarz, LLC.

clock 3:15 pm - 3:30 pm EST

Understanding How Doubt-as-to-Liability Offers Work

Eric L. Green

Green & Sklarz, LLC.

Examine the mechanics of doubt-as-to-liability offers using Form 656-L and how they differ from audit reconsideration. Learn when this approach is most effective, particularly for trust fund assessments, and understand why collection stops immediately upon filing.

Eric L. Green

Green & Sklarz, LLC.

clock 3:30 pm - 3:45 pm EST

Utilizing CDP Hearings to Force Liability Reconsideration

Eric L. Green

Green & Sklarz, LLC.

Discover how Collection Due Process hearings can be used to challenge underlying tax liability when it’s the taxpayer’s first opportunity to do so. Learn the strict requirements for proving no prior opportunity existed and the importance of timely filing Form 12153.

Eric L. Green

Green & Sklarz, LLC.

clock 3:45 pm - 4:00 pm EST

Using Refund Requests to Reopen Bad Assessments

Eric L. Green

Green & Sklarz, LLC.

Explore the pay-and-claim-refund strategy as the only guaranteed method to force court review of a disputed assessment. Understand the procedural requirements, timing rules, and how to choose between Federal District Court and the Court of Federal Claims.

Eric L. Green

Green & Sklarz, LLC.

01 05
Prev
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speakers

Joe Ervin

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Kevin Foley

Reminger Co
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Grant H. Lawson

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Eric L. Green

Green & Sklarz, LLC.

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

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.

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