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2022 72nd Midyear Conference

T15 - Alarming Trends in Penalty Assertions: When Did Penalties Become Their Own Substantive Issue?

Mar 22, 2022 3:45pm ‐ Mar 22, 2022 4:45pm


It’s no secret that the IRS is pursuing a reinvigorated approach to asserting penalties. Penalty assertions are rising at significant levels, and tactics for challenging them are also changing. In response, TEI has assembled an experienced team of leading professionals to drill down on this concerning trend and provide the tools and skills you need to effectively manage penalties. Our panel will overview substantive developments in the IRS’s application of penalties in the areas of income tax; information reporting, including international information return penalties; and employment tax, addressing topics such as, substantial authority, penalty stacking, and handling penalties separate from substantive adjustments. The panel will then shift to important procedural developments impacting how taxpayers can effectively challenge penalty assertions at Exam, Appeals, and in collection cases. In doing so, our panelists will provide best practices for working with the IRS in today’s challenging environment where Exam teams are working remotely, IRS service centers have extreme backlogs, and historic methods of communication may not be effective.

At the conclusion of this course, participants should:

  • Have a working knowledge of the different types of penalties, factors for asserting them, and instances in which multiple penalties can apply to a single return item;
  • Be aware of recent trends in penalty assertions and how the current environment differs from past practice;
  • Understand the different defenses to penalties and strategies for working within the chain of command at Exam to resolve them;
  • Gain insights on strategies for using penalty assertions to resolve other issues in a case both at Exam and Appeals;
  • Gain awareness of resolution options and procedural complexities once the IRS commences collection actions;
  • Be aware of unique challenges taxpayers face in the current environment of significant delays and have strategies for resolving penalty cases in this environment




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