Super Conference 2024

IRS representation is what we do, it’s our passion. We are a community of advocates, thinkers, and problem solvers, relentlessly committed to standing up for those facing the IRS machine.

Our mission resonates in every action we take: to champion our clients’ rights with unwavering confidence and unparalleled proficiency. This is not just a goal – it’s our promise to each other and to those we serve.

Many of us have been waiting for the IRS to increase enforcement activity, and the wait is over. This year we have seen a drastic increase in the number of representation cases in our community. Now more than ever it is critical that we gather to share insights and strategies to propel us forward.

Together, we forge ahead, not just with a sense of purpose, but with a vibrant eagerness to both defend our client’s rights and embrace growth opportunities for our careers.

Presented by Larry Lawler, CPA, EA, CTRS

This course that delves into the essential strategies and procedural steps needed to challenge an IRS Offer in Compromise (OIC) denial. After this course, participants will gain a clear understanding of how to craft effective protest letters, navigate the appeals process, and engage with the IRS to seek a favorable resolution.

Larry will cover critical details of the protest process, how to structure compelling arguments, and what to expect during OIC appeals. Attendees will leave with the knowledge and skills to confidently manage OIC protests and appeals, increasing their chances of success for clients.

Key Learning Outcomes from the Program:

• Protest Letter Essentials: Learn how to craft a detailed and persuasive protest letter that addresses the IRS’s reasons for OIC denial and presents a strong case for reconsideration.
• Appeals Process Navigation: Understand the procedural steps of the OIC appeals process, including timelines, documentation requirements, and strategies for presenting your case to the IRS appeals office.
• Strategic Insights: Gain practical insights into what makes an OIC appeal successful and how to anticipate and respond to common challenges in the appeals process.

Presented by Angelene Wierzbic, EA, CTRS

This course focuses on leveraging the concept of Hazards of Litigation to secure favorable outcomes for clients. While the word “hazard” may typically trigger concern, in the context of IRS cases, raising these hazards can be a strategic advantage.

Angelene Wierzbic, EA, CTRS, will guide participants through the IRS Appeals process, where the odds of success in court are weighed to assess potential settlements. By highlighting the risks the IRS faces in litigation, practitioners can improve their clients’ chances of reaching better settlements, particularly in cases involving Tax Court or the potential for legal action.

Key Learning Outcomes from the Program:

• Understanding Hazards of Litigation: Learn what Hazards of Litigation are and how they influence settlement decisions in IRS Appeals.
• Application Scenarios: Identify the types of cases where an analysis of Hazards of Litigation is relevant and beneficial.
• Research and Legal Strategies: Gain tips on researching legal precedents and using them to bolster your case.
• Factual Argument Presentation: Master the skill of presenting strong factual arguments to appeal to the IRS’s assessment of risk.
• Negotiation Techniques: Learn effective strategies for negotiating with IRS Appeals, using Hazards of Litigation to your advantage.

Presented by LG Brooks, EA, CTRS

This course is designed to introduce practitioners to a lesser-known but highly valuable option in the IRS Collection Due Process (CDP) framework: the Retained Jurisdiction Hearing. This type of hearing allows the IRS Independent Office of Appeals to re-engage in cases where prior decisions or mandates were not properly implemented by the IRS Collection Function, without the need for a Post Appeals Mediation request.

Participants will learn the specific guidelines required to qualify for a Retained Jurisdiction Hearing, including the authority it provides to enforce prior Appeals decisions, address post-Tax Court rulings, and handle new circumstances that arise after an Appeals determination.

Key Learning Outcomes from the Program:

• Retained Jurisdiction Procedures: Understand the necessary steps and legal foundations (IRC, Treasury Regulations, and Internal Revenue Manual) for properly requesting a Retained Jurisdiction Hearing.
• Enforcing Appeals Decisions: Gain insights into how Retained Jurisdiction can compel the IRS Collection Function to implement previous Appeals decisions.
• Post-Tax Court and Appeals Actions: Learn how to address additional issues that arise after a Tax Court decision or other Appeals matters using Retained Jurisdiction.
• Strategic Utilization: Explore how this “third wheel” in the CDP process can benefit tax cases and be used more frequently than traditional post-Appeals procedures.

Presented by Darren Guillot (former Commissioner of IRS SBSE)

examines the IRS’s evolving strategies for high wealth taxpayers, including the integration of artificial intelligence (AI) into decision-making processes and remote interactions with taxpayers. Hear directly from a leader involved in some of the IRS’s first successful high-wealth compliance initiatives and discover how AI is reshaping the future of IRS compliance.

The former Commissioner of IRS SBSE will also dive into the impact of the post-COVID environment on collection programs, including the pause and restart of collection notices, updates on COVID-era credits like the Employee Retention Credit (ERC), and alternative resolution options that are gaining traction among wealthy taxpayers aiming to resolve their tax liabilities.

Key Learning Outcomes from the Program:

• High Wealth Compliance Initiatives: Learn about the IRS’s focused strategies for high wealth taxpayers and how AI is influencing compliance efforts.
• AI in Decision Analytics: Explore how AI is being used to analyze taxpayer behavior and what it means for the future of IRS interactions and enforcement.
• Post-COVID Collection and Appeals Programs: Understand the impact of the pause and restart of collection notices and the latest updates on COVID-era credits such as the ERC and credits for sick and family leave.
• Creative Resolution Alternatives: Discover new resolution strategies that are becoming increasingly popular among high wealth taxpayers as they navigate IRS compliance post-COVID.

Presented by Steve Klitzner, Esq., CTRS

This course provides an in-depth look at the IRS’s authority under IRC §7345 to certify taxpayers with seriously delinquent tax debt to the State Department, leading to potential passport denial, revocation, or limitations. Miami Tax Attorney Steven Klitzner will guide participants through the critical steps necessary to safeguard clients’ passports and reverse certifications when needed.

By the end of this course, participants will be equipped to recognize and prevent passport certification issues and take corrective action to restore their clients’ travel privileges.

Key Learning Outcomes from the Program:

• Identification of At-Risk Taxpayers: Learn how to spot clients who are at risk of having their passports revoked or denied due to seriously delinquent tax debt.
• Preventive Measures: Understand the steps practitioners can take to prevent passport certification and protect clients’ travel rights.
• Certification Reversal Procedures: Master the process of reversing passport certification, including documentation and IRS communications.
• Expedited Decertification: Gain insights on how to expedite the decertification process when a client’s passport is under threat.

Presented by Deborah Weber, Esq.

Every tax professional has encountered cases that leave a lasting impression—cases that are more memorable and complex, where the only fitting response afterward is, “Well, that was interesting!” In this session, I’ll share a selection of unique and challenging cases from my 33 years of representing taxpayers before the IRS and the NYS Tax Department. For each case, I will walk through the key issues, the final outcomes, and the unexpected twists that arose along the way.

Key Learning Outcomes from the Program:

• How to analyze and focus a difficult or challenging case towards a reasoned and direct solution (when possible).
• Red Flags or signs that a cookie cutter vanilla case might really be a rocky road banana split decked out with homemade whip cream and cherries.
• Ethical considerations that often exist or arise in challenging cases that you might not see coming.

Presented by Aiysha Hayes, EA

This course is designed to provide practitioners with the knowledge, skills, and tools to effectively engage with IRS Revenue Officers (ROs). By understanding the RO’s objectives, challenges, and how to influence their view of the case, practitioners will learn how to steer the case toward successful outcomes. This session will show you how to build a productive, positive relationship with Revenue Officers—one where they look forward to working with you.

After attending this session, practitioners will be able to:

• Direct Case Outcomes: Learn how to lead Revenue Officers toward your desired case resolutions.
• Strategic Case Planning: Master the ability to clearly develop and communicate a plan of action that involves both your client and the RO.
• Building Trust and Rapport: Employ strategies that build trust, respect, and strong working relationships with the RO.
• Effective Tools for Case Management: Leverage analytical tools to assist with case summaries and present compelling arguments.

Presented by Gregory Nunn, CPA, CTRS & Angelene Wierzbic, EA, CTRS

With IRS finally having a budget to hire staff, we are going to be exposed to more and more new IRS employees.  While the IRS does train new hires, a lot of what they learn comes from on the job experience.  As seasoned practitioners, we are going to be placed in the position of having to offer knowledge that these newbies have not been exposed as yet.  Knowing how to support our positions and communicate our knowledge is going to be more important than ever.

During this session, we will role play some scenarios between a practitioner and IRS personnel.  We will focus on techniques to properly impart our years of wisdom to new staff.

In this session you will learn:

• Tips to recognize new employees
• Tips on communication techniques
• Providing cites and research
• Recognizing when to elevate the case

Presented by Billy Fauller, III, EA, CTRS

While many practitioners are familiar with the basics of disclosure and FOIA, understanding which documents fall under each can be more nuanced. There are certain simple documents you can’t request directly, while some highly technical ones are available through FOIA. Do you know when to apply FOIA versus disclosure to obtain the information you need?

This program will provide a solid foundation on the differences between disclosure and FOIA, teaching you how to navigate both processes. You’ll learn which documents can be requested directly and how to leverage FOIA for those you cannot.

Key Learning Outcomes from the Program:

• Understanding Disclosure: Learn the basics and key principles of IRS disclosure.
• When to Use Disclosure vs. FOIA: Gain clarity on when to use each and why it matters.
• Document Classification: Know which documents are accessible through disclosure versus FOIA.
• FOIA Process Walkthrough: Get a step-by-step guide on submitting FOIA requests.
• Leveraging FOIA for DLN Info: Learn how to use FOIA to access Document Locator Number (DLN) information.

Presented by Michael Sardar, JD

Even the simplest IRS audit carries inherent risks, but when an audit reveals significant income underreporting, deficiencies, or potential fraud, the challenges multiply. In high-stakes audits, the consequences can extend beyond additional tax or penalties, potentially implicating a taxpayer’s liberty. This session provides strategies to minimize the risks associated with sensitive audits and offers guidance on recognizing when an audit may escalate into a criminal investigation. You will also learn how to manage issues of privilege and the taxpayer’s 5th Amendment rights during the process.

Key Learning Outcomes from the Program:

• Identifying Sensitive Audits: Learn how to recognize when an audit has the potential to become high-risk.
• Critical Questions: Understand the essential questions to ask both the IRS auditor and your client.
• Criminal Investigation Referrals: Gain tips for recognizing when an IRS Examiner has referred your client for a criminal investigation.
• Preserving Client Privileges: Master strategies to preserve the client’s legal privileges during the audit.
• Managing Tax Reporting During an Audit: Learn how to handle current tax reporting obligations without creating further complications.

Presented by Elizabeth Holladay, EA, CTRS

This session focuses on strategies for handling cases where IRS agents or officers are uncooperative or when traditional methods fail to resolve an issue. In these situations, it’s essential to employ advanced tactics to keep your case moving forward.

Whether it’s requesting a managerial review, escalating to the Appeals Office, engaging Congress, or utilizing the Taxpayer Advocate Service or Stakeholder Liaison, knowing when and how to escalate a case can be the key to a successful outcome. This session will explore how to use these advanced approaches effectively to break through bureaucratic barriers.

Key Learning Outcomes from the Program:

• How to recognize when traditional resolution tactics are no longer effective.
• Strategies for requesting managerial reviews and elevating cases to the Appeals Office.
• The role of the Stakeholder Liaison and how they can assist with case resolution.
• When and how to engage Congress or the Taxpayer Advocate Service.
• Real-world examples of successful escalations and case resolutions.

Presented by Jim Cunningham, JD

Succession planning is vital because it ensures a smooth transition of business ownership and leadership in the event of an owner’s death, retirement, or unexpected departure. Without a plan, businesses may face legal challenges like probate, disrupted operations, client loss, and potential financial strain on the owner’s family.

It also protects the company’s legacy, provides clear direction to employees, and secures the company’s long-term survival by identifying future leaders or successors, whether family members, key employees, or external buyers. Proper planning helps minimize uncertainty and chaos.
In this presentation, we’ll explore:

Key Learning Outcomes from the Program:

• Important strategies for business transitions
• Importance of estate planning and Power of Attorney management, including filing and revoking forms (2848).
• Practical insights on legal requirements for CPAs, file transfers, and business hygiene to maintain operational readiness following the AIPA Guidelines.

Presented by J “Anton” Collins, Attorney, LLM (Tax), Former IRS

The session method allows the netting of gambling wins and losses, which can result in much lower gross winnings and taxes owed. However, this option for gross income calculation still seems somewhat mysterious, as tax professionals have been hesitant to employ the sessions method. This topic intends to explain the rules, calculations, and applications for both federal and state tax returns.

Key Learning Outcomes from the Program:

• What (and why) is the gambling sessions method?
• How do you calculate and prepare returns with a “gambling sessions” election?
• How does it affect a tax client’s federal tax and state tax?
• How do you explain it (and sell it) to tax clients?

At the start of the Super Conference we will take some time to reflect on the past 12 months and what has happened in the industry. We’ll cover important IRS updates that effect your business and the outlook for the next year!

Our members LOVE the monthly Office Hours call. Well this year we’re bringing it to the Super Conference! Over the course of an hour Larry, Steve, and LG will answer 15 pre-submitted case questions from audience members!

Join us for an evening of fun and networking. After the first day of the conference, we will have a wonderful evening of food, drinks, and tax resolution talk! This is included in your ticket.