Celesq® Programs

Uncommon Strategies for Dealing with the IRS Appeals Office from a Tax Litigators Perspective

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With the current filing of the first returns under the Tax Cuts & Jobs Act of 2017 (TCJA), taxpayers can expect increased IRS scrutiny in the future and the submission of more cases to the IRS Appeals Office. This presentation, by three tax litigators, will focus on strategies for dealing with the IRS Appeals under the updated Appeals Judicial Approach and Culture (AJAC) Project as well as the Taxpayer First Act of 2019 (TFA). Through the AJAC Project and TFA, IRS Appeals has updated its policies and procedures to reinforce its role as a quasi-judicial forum. This presentation will address those policies and strategies for large businesses to consider, including:(i) What changes to Appeals can be expected from TCJA and the TFA; (ii) New strategies for handling potential unagreed IRS exams going to Appeals under AJAC; (iii) How to resolve a case with IRS Appeals that is docketed in U.S. Tax Court; (iv) How AJAC policies impact LB&Is Acknowledgement of Facts (AOF) IDR; and (v) Strategies for dealing with the new policy of having LB&I Exam and/or IRS Counsel attending Appeals conference.

Available in States

  • California
  • Georgia
  • New Jersey
  • New York
  • Texas Self Study

Program Categories

  • Administrative Law & Regulations
  • Banking & Finance Law
  • Business Law
  • Complex Litigation
  • Corporate and Securities Law
  • Federal Courts
  • Financial Regulatory
  • Financial Services
  • In-House Counsel
  • Litigation & Litigation Skills
  • Taxation Law
  • Trial Skills