The Tax Professional Empowerment Seminars

The Tax Professional Empowerment Seminars consist of four unique and informative courses covering several major areas of taxation laws, procedures and strategies. Each seminar provides an in-depth reveal of its topic and equips the learner with the knowledge to address these matters with confidence.

 The Four Courses...
 

Tax Court Procedure

Very few non-attorney tax practitioners know that they can practice in the U. S. Tax Court once they successfully meet the criteria to sit for and pass the Tax Court Examination.


This seminar deals with the procedure of representing a client’s tax controversy in U.S. Tax Court. The discussion is geared to provide insight into improving the success rate of tax dispute negotiations and to increase knowledge of the U.S. Tax Court, as well as prepare for the Tax Court examination.

Included in this seminar:
 
 • The Organization of the U. S. Tax Court
 • Statutory Notice of Deficiency
    * Last Known Address
    * Due Process Hearing
 • Tax Court Jurisdiction
    * Choice of Forum
 • U.S. Tax Court Rules of Practice & Procedure
 • Procedure for filing a U.S. Tax Court petition
 • Pleadings
 • The Office of Chief Counsel
 • Motions, Pre-Trial Fact Development, Discovery
 • Procedure During Trial
    * Burden of Proof
 • Small Tax Case Procedure
 • U.S. Tax Court Brief

The IRS and Tax Controversy Process

When a tax controversy arises, the client needs representation that has knowledge as to the process as well as on the actual tax matter. This seminar emphasizes the structure and purpose of each step in the adversarial process. Included in the course, as outlined, is when does the tax matter reach a level that mandates filing a U. S. Tax Court petition.

Included in this seminar:
 
 • IRS Organization
 • Functional Units
    * National Taxpayer Advocate
    * Criminal Investigation
    * Appeals
 • Operating Divisions
    * Wage & Investment
    * Small Business/Self-Employed
    * Large & Mid-size Business
    * Tax Exempt & Government Entities
 • Compliance Organization Structure
 • Practice Before the IRS and Preparer Penalties
    * Powers of Attorney
    * Preparer Penalties and Disciplinary Actions
    * Adequate Disclosure, "Reasonable Cause","Good Faith","Willful Negligence"
 • Examination of Returns and IRS Investigating Powers:
   Trends & Benchmarks
 • IRS Appeals
    * Protest Process
    * Settlement in Appeals
    * Closing Agreements
 • Liens, Levys and The Collection Due Process Procedure
 • U.S. Tax Court
    * Tax Court Jurisdiction and the Courts that Impact a Tax Case
    * Small Case
    * Deficiency vs. Refund
    * Employment Determination
    * Which Court to Choose and Why

Special Partnership Issues

This seminar deals with the special issues unique to "partnerships". Specifically, this day seminar looks at Partnership Audits, Notice Partners, Tax Matter Partners, 1982 TEFRA, Responsible party and more.

The material includes adjustments at the partner level, judicial determination of issues relating to partnership items and determination as to who is the party, or parties, to the proceeding.

Included in this seminar:
 
 • Notice Partners
    * Who is a member of a "5-percent group" under the Code?
 • Tax Matters Partner
    * Duties Unique to Tax Partners
    * First Right to Commence Litigation
 • Audits
    * Procedure
    * Rights of the Parties
    * Statute of Limitation
 • Responsible Parties
    * What Happens When the Partnership is Dissolved?
 • Forum Shopping that is Unique to Partnerships
    * Venue Considerations
    * Interpleader
 • Special Statutory Notice Issues in Partnerships

Tax Court Procedure

Very few non-attorney tax practitioners know that they can practice in the U. S. Tax Court once they successfully meet the criteria to sit for and pass the Tax Court Examination.


This seminar deals with the procedure of representing a client’s tax controversy in U.S. Tax Court. The discussion is geared to provide insight into improving the success rate of tax dispute negotiations and to increase knowledge of the U.S. Tax Court, as well as prepare for the Tax Court examination.

Included in this seminar:
 
 • The Organization of the U. S. Tax Court
 • Statutory Notice of Deficiency
    * Last Known Address
    * Due Process Hearing
 • Tax Court Jurisdiction
    * Choice of Forum
 • U.S. Tax Court Rules of Practice & Procedure
 • Procedure for filing a U.S. Tax Court petition
 • Pleadings
 • The Office of Chief Counsel
 • Motions, Pre-Trial Fact Development, Discovery
 • Procedure During Trial
    * Burden of Proof
 • Small Tax Case Procedure
 • U.S. Tax Court Brief