Program Details
2025-09-18 15:00:00
Over 1,000+ webinars
Course Overview
2025-09-18 15:00:00
1h CLE Credits
Intermediate
1
3:00 pm - 3:05 pm ESTLearn 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. 3:05 pm - 3:15 pm ESTUnderstand 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. 3:15 pm - 3:30 pm ESTExamine 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. 3:30 pm - 3:45 pm ESTDiscover 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. 3:45 pm - 4:00 pm ESTExplore 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.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.
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.
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
