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Mastering IRS Representation: Notice of Deficiency…Now What?

MASTERING IRS REPRESENTATION: NOTICE OF DEFICIENCY…NOW WHAT?

Cost Free
Presentation Length 1.0 hour

Recorded DateAugust 11, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Your client received the request for supporting documentation and you dutifully submitted it by the deadline. Instead of a letter thanking you for being so diligent, instead arrives a dreaded Notice of Deficiency, telling your client they believe they owe money and giving you 90 days to file in the United States Tax Court. Why? It’s almost as if a human being did not even look at what you sent. This program will review the process for challenging the Notice of Deficiency, including the process from Tax Court, and what to do if the Tax Court deadline is missed.

Learning Objectives:


  • Recognize the purpose and implications of a Notice of Deficiency

  • Determine the necessary steps and procedures for challenging a Notice of Deficiency

  • Identify the potential consequences and available options when the deadline for filing is missed, and list strategies for mitigating the impact mitigating the impact

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Eric is a partner in Green & Sklarz LLC, a boutique tax firm with Connecticut and New York offices. The focus of Attorney Eric L. Green's practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service, and state Departments of Revenue Services. His practice also handles probate matters and estate planning for individuals and business owners, and tax planning for closely-held businesses. He is a frequent lecturer on tax topics for CCH, the NAEA, the NATP, the ABA Tax Section, and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He is the author of The Accountant's Guide to IRS Collection (available www.tgpublish.com), and he is a columnist for CCH's Journal of Practice & Procedure. He is also the founder of The New England IRS Representation Conference. Mr. Green is a contributing author for Advocating for Low-Income Taxpayers: A Clinical Studies Casebook, 3rd Edition, and has also been quoted in The Wall Street Journal, USA Today, Consumer Reports, The Wall Street Journal's Market Watch, TheStreet.com, and CreditCard.com. Before practicing law Attorney Green served as a senior tax consultant for KPMG and Deloitte & Touche. Attorney Green was the 2010 Nolan Fellow of the American Bar Association and has served as Chair of the American Bar Association's Closely Held Businesses Tax Committee. Attorney Green is the current Chair of the Executive Committee of the Connecticut Bar Association's Tax Section. Eric is a Fellow of the American College of Tax Counsel ("ACTC") and a Connecticut, Massachusetts, New York, and American Bar Association member. He is admitted to practice in Massachusetts, New York, and Connecticut Superior Courts, as well as the United States Tax Court, the Federal Court of Claims, and the Federal District Court for Connecticut. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honor graduate from New England School of Law. He earned a Masters of Laws in Taxation (LL.M.) from Boston University School of Law.


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