The number of tax penalties assessed by the Internal Revenue Service has increased dramatically over the past several years. For example, assessments of accuracy-related penalties against individuals and corporations rose from 59,708 in 2005 to 472,961 in 2010, a nearly 800% increase! At the same time, the Internal Revenue Service is focusing more than ever before on the conduct of professionals, through return preparer penalties, Circular 230 enforcement and even criminal prosecutions. Sophisticated and responsible practitioners engaged in tax planning or tax controversies must understand where the lines are drawn and consider application of penalties when appropriate. However, accounting and law school tax classes rarely focus on penalties, leaving practitioners to pick up the relevant standards and procedures from the trial and error of daily practice.
This new seminar is a unique opportunity to review the various tax penalties that can be imposed, the standards and transactions that can trigger penalties and sanctions, the procedures the Internal Revenue Service must follow to assess penalties and the defenses that can be asserted. We have assembled an expert faculty of experienced private practitioners and government representatives to explain how penalties work, why they are assessed and how you can protect yourself and your client.
Lecture Topics [Total time 06:22:49]
Segments with an asterisk (*) are available only with the purchase of the entire program.
- Introduction and Opening Remarks* [00:26:18]
Bryan C. Skarlatos
- Delinquency & Accuracy-Related Penalties [01:29:57]
Bryan C. Skarlatos, John V. Cardone, Lisa Flores, Barbara T. Kaplan, Sally A. Sattan
- But It's Not My Fault: Reasonable Cause Defenses [01:00:52]
Roland Barral, Diana L. Wollman
- Reportable Transaction Penalties & Foreign Financial Asset Penalties [01:28:28]
Megan L. Brackney, Ian M. Comisky, John C. McDougal, Maria T. Stabile, Michael A. Halpert
- Special Rules for the Professionals: Return Preparer Penalties and Ethical Standards [00:59:48]
Professor Linda Galler, Emily M. Lesniak
- Crossing the Line: Civil and Ciminal Tax Fraud [00:57:26]
Frank Agostino, Kathleen M. Pakenham, Daniel W. Levy
The purchase price of this Web Program includes the following articles from the Course Handbook available online:
- Delinquency Penalties
Bryan C. Skarlatos
- Accuracy Related Penalties
Bryan C. Skarlatos
- Reasonable Cause
Bryan C. Skarlatos
- Reportable Transaction Penalties
Bryan C. Skarlatos
- Foreign Financial Asset Penalties
Bryan C. Skarlatos
- I Had to Report That? Foreign Financial Asset Penalties
Ian M. Comisky
- Foreign Financial Asset Tax Forms and Instructions
Bryan C. Skarlatos
- Special Rules for the Professionals: Return Preparer Penalties and Ethical Standards
Professor Linda Galler
- Civil and Criminal Tax Fraud
Kathleen M. Pakenham
- Index to Nuts and Bolts of Tax Penalties 2013
Presentation Material
- Accuracy-Related Penalties
John V. Cardone, Lisa Flores, Barbara T. Kaplan
- Skarlatos-Delinquency Penalties
Bryan C. Skarlatos
- Wollman-But Its Not My Fault
Diana L. Wollman
- Brackney-Now That's Aggressive
Megan L. Brackney
- Comisky-Foreign Financial Assets
Ian M. Comisky
- Special Rules for Tax Professionals: Return Preparer Penalties and Ethical Standards
Professor Linda Galler
- Agostino-Crossing the Line
Frank Agostino
- Crossing the Line: Civil and Ciminal Tax Fraud
Frank Agostino
- Pakenham-Crossing the Line
Kathleen M. Pakenham
Chairperson(s)
Speaker(s)
Roland Barral ~ Area Counsel, (LB&I - Financial Services), Office of Chief Counsel, Internal Revenue Service
John V. Cardone ~ Deputy Area Counsel (Small Business/Self-Employed Division), Internal Revenue Service
Lisa Flores ~ Deputy Area Counsel (Strategic Litigation); LB&I, Area 1 (Financial Services), Internal Revenue Service
Michael A. Halpert ~ Program Manager, Team 1220 for Tax Shelter Promoter Compliance Specialists (LB&I-Financial Services), Internal Revenue Service
Emily M. Lesniak ~ Attorney (Procedure and Administration), Internal Revenue Service
John C. McDougal ~ Special Trial Attorney, Office of Chief Counsel, Internal Revenue Service
Sally A. Sattan ~ Staff Attorney, Low-Income Taxpayer Clinic, Northeast New Jersey Legal Services
Maria T. Stabile ~ Associate Area Counsel (LB&I, Financial Services), Internal Revenue Service
PLI makes every effort to accredit its On-Demand Web Programs and Segments. Please check the CLE Calculator above for CLE information specific to your state.
On-Demand Web Programs and Segments are approved in:
Alabama1, Alaska, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho*, Illinois , Iowa2*, Kansas, Kentucky*, Louisiana, Maine*, Mississippi, Missouri3, Montana, Nebraska, Nevada, New Hampshire4, New Jersey, New Mexico5, New York6, North Carolina7, North Dakota, Ohio8, Oklahoma9, Oregon*, Pennsylvania10, Rhode Island11, South Carolina, Tennessee12, Texas, Utah, Vermont, Virginia13, Washington, West Virginia, Wisconsin14 and Wyoming*.
Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.
Minnesota approves live webcasts ONLY
Please Note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. PLI programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.
*PLI will apply for credit upon request. Louisiana and New Hampshire: PLI will apply for credit upon request for audio-only on-demand web programs.
1Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.
2Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.
3Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.
4New Hamphsire: The approval is for three years from recorded date.
5New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.
6New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web Programs or live Webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.
7North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.
8Ohio: To confirm that the web program has been approved, please refer to the list of Ohio’s Approved Self Study Activities at http://www.sconet.state.oh.us. Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.
9Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.
10Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.
11Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.
12Tennessee: The approval is for the calendar year in which the live program was presented.
13Virginia: All distance learning courses are to be done in an educational setting, free from distractions.
14Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.
Running time and CLE credit hours are not necessarily the same. Please be aware that many states do not permit credit for luncheon and keynote speakers.
If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.
Note that some states limit the number of credit hours attorneys may claim for online CLE activities, and state rules vary with regard to whether online CLE activities qualify for participatory or self-study credits. For more information, call Customer Service (800) 260-4PLI (4754) or e-mail info@pli.edu.