IRS Nonfiler Representation – Representing Taxpayers Who Have Not Filed Tax Returns!

Addressing Nonfiler Cases from Penalty Abatement to Criminal Investigation

Many taxpayers face significant challenges when they fail to file tax returns for one or more years. Non-filers are at risk of severe consequences, including monetary penalties, criminal charges, and the IRS filing substitute returns on their behalf, often leading to exaggerated tax liabilities. This webinar addresses these critical issues and guides professionals on how to effectively represent non-filers and navigate the complexities of IRS procedures.

This webinar, led by Tax attorney Adam Fayne, provides comprehensive strategies for representing non-filers. It covers the essential steps to advise clients on filing delinquent returns, mitigating penalties, and reducing exposure to criminal prosecution. Participants will learn how to leverage IRS policies to their advantage, including the six-year filing rule and methods for handling substitute returns filed by the IRS.

Webinar Objectives

• Comprehensive Understanding: Develop a clear strategy for advising clients on how to approach unfiled tax returns, including the timing and process of filing.

• Reasonable Cause Statements: Learn how to prepare and file compelling reasonable cause statements alongside unfiled returns to help avoid penalties and ensure compliance with IRS standards.

• Penalty Abatement Techniques: Master techniques to request penalty abatements for unfiled and late returns, reducing financial burdens on your clients.

• Audit and Collection Strategies: Discover best practices for addressing unfiled returns during IRS audits and collections, minimizing adverse outcomes.

• Navigating Criminal Investigations: Gain crucial knowledge on how to handle situations where unfiled returns have escalated to criminal investigations, protecting your clients from severe legal consequences.

By the end of this session, you will be well-prepared to guide your clients through the complexities of resolving unfiled tax returns, ensuring they avoid unnecessary penalties and legal risks.

Webinar Agenda

• Introduction to Nonfiler Representation

  • Understanding the profile of a non-filer
  • Overview of IRS procedures and consequences for non-filing

• Critical Considerations for Non-filers

  • Should clients file now or wait until they have the money to pay?
  • Strategies for starting the statute of limitations

• Best Practices for Filing Delinquent Returns

  • How many years to go back: The six-year filing policy
  • Techniques for submitting multiple years of returns to avoid increased scrutiny

• Handling IRS Substitute for Returns (SFR)

  • What SFRs are and why they are detrimental to clients
  • Steps to rectify SFRs and reassess liabilities

• Penalties and Criminal Exposure

  • Understanding the risk of penalties and criminal charges
  • Reasonable cause arguments and how to apply them

• Conclusion and Q&A Session

  • Open floor for participant questions
  • Additional resources and contact information for follow-up

Webinar Highlights

• The available processes to file unfiled returns
• Contesting penalties assessed or proposed related to the unfiled returns
• How to put forth a reasonable cause defense to penalties
• Civil versus criminal risk with unfiled returns
• How to address unfiled domestic and foreign information returns

Who Should Attend

Accountants, tax preparers, CFOs, financial compliance professionals, and lawyers

Credit(s)

IRS CPE Credits: 1 Tax hour