IRS Penalties: Advanced Assessment, Appeals, and Defense

Categories: IRS CE, IRS Resolution
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About Course

This two-hour advanced continuing education course equips tax professionals with the procedural and substantive command needed to defend a client against a federal tax penalty — from the moment a penalty is first proposed through a Collection Due Process hearing or Tax Court petition. The course is built for enrolled agents and other tax return preparers who already handle penalty matters and want to represent clients facing penalty assessment, examination, or appeals with confidence.

Participants examine the distinction between deficiency and assessable penalties, the IRC §6751(b) supervisory approval requirement, the specific statutory defenses to the accuracy-related penalty and the government’s burden to sustain a civil fraud penalty, domestic and international information return penalty regimes including FBAR, and Collection Due Process hearing and Tax Court strategy for a contested penalty.

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What Will You Learn?

  • Distinguish deficiency penalties from directly assessable penalties and identify the applicable procedural path for each
  • Apply the IRC §6751(b) written supervisory approval requirement as a procedural penalty defense
  • Apply the specific statutory defenses available against an accuracy-related penalty under IRC §6662
  • Identify the burden of proof the IRS bears to sustain a civil fraud penalty under IRC §6663
  • Apply the penalty regimes applicable to domestic and international information returns, including FBAR
  • Apply Collection Due Process hearing and Tax Court petition strategy to a contested penalty

Course Content

Module 1 – Penalty Assessment Procedures: Deficiency vs. Assessable Penalties
This module covers the procedural distinction between deficiency penalties and directly assessable penalties, and the IRC §6751(b) written supervisory approval requirement as a procedural defense, including the current §301.6751(b)-1 timing rules.

  • Penalty Assessment Procedures: Deficiency vs. Assessable Penalties

Module 2 – Defending Against Accuracy-Related and Civil Fraud Penalties
This module covers the specific statutory defenses to the §6662 accuracy-related penalty — reasonable cause, adequate disclosure, and reliance on a tax professional — and the government's clear and convincing burden to sustain a §6663 civil fraud penalty.

Module 3 – Information Return and International Penalty Regimes
This module covers domestic information return penalties under §6721/§6722, the international penalty regimes for Form 5471, Form 5472, and Form 3520, and FBAR penalties under the Bank Secrecy Act, including the Supreme Court's Bittner decision.

Module 4 – Appeals Strategy and Tax Court Defense for Contested Penalties
The final module covers Collection Due Process hearing mechanics under §6330, including the prior-opportunity limitation on challenging liability, penalty-specific Appeals strategy, and Tax Court petition strategy for a penalty-only dispute.

Final Assessment – IRS Penalties: Advanced Assessment, Appeals, and Defense
You have completed an advanced review of federal tax penalty assessment procedures, penalty defense, and appeals strategy, covering deficiency versus assessable penalties, accuracy-related and civil fraud penalty defenses, information return and international penalty regimes, and Collection Due Process and Tax Court strategy for a contested penalty. You are now prepared to demonstrate your understanding of the key concepts. The following final examination assesses your knowledge of the material covered in all four modules. A passing score of 70% is required to successfully complete the course.

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