Defending Against IRS Collections

Defending Against IRS Collections - Part 1 & 2

January 2010

Defending Against IRD Collections - Part 1 & 2

Program Description

One of the worst days in the life of an individual taxpayer or small business is when the IRS begins collection activities to collect past due taxes. Armed with wide powers to freeze and seize assets, the IRS collection activities can have a devastating impact on an individual or small business’s operations. The distress is particularly acute when the taxpayer has failed to remit payroll taxes and is liable for the Trust Fund Recovery penalty. This program will provide the non-tax specialist with a practical guide to the process and timeline of IRS collections, how to obtain information from and respond to the IRS, issues when the taxpayer is in bankruptcy, and special issues related to the Trust Fund Recovery penalty, and much more.

Topics Day 1 - January 19, 2010

- How the collection process works for individual taxpayers and small businesses

- Taxpayer bankruptcy issues

- Understanding liens and levies

- Requesting taxpayer return and records from the IRS

- Practical guidance on responding to the IRS at each stage of the process

Topics Day 2 - January 20, 2010

- Small business, economic distress, and Trust Fund Recovery penalties

- Negotiating with the IRS when the taxpayer cannot pay

- Settlement alternatives, including installment agreements

- Penalty abatements & injunctive relief from collections

- Appeals process

Faculty

Charles "Chuck" E. Hodges, II is a partner in the Atlanta office of Chamberlain Hrdlicka, LLP, where he concentrates his practice in civil and criminal federal tax controversies and complex tax planning. He has been involved in over 100 cases against the IRS involving all areas of tax law, representing a broad range of taxpayers from individuals, estates and partnerships to publicly-traded corporations. Mr. Hodges has been a key litigator in various cases earning him honors such as a “Leader in the Field” of Taxation by the 2005 and the 2006 Chambers USA—America’s Leading Lawyers for Business as well as a “Georgia Super Lawyers Rising Star” for 2005, 2006, and 2007. He received his B.S., cum laude, from Clemson University, his J.D. from Mercer University, and his LL.M. from the University of Florida.

Matthew L. Kadish is a partner in the Cleveland office of Kadish, Hinkel & Weibel, LPA, where he has an extensive tax, estate planning and business transactions practice. He has represented individual and business clients in a wide variety of tax-related planning, including choice of entity, business succession, estate, charitable giving, exempt organizations, retirement planning and IRS controversy cases. Mr. Kadish has been named an “Ohio Super Lawyer” and is vice president of litigation of the Small Business Council of America. Before entering private practice, he served as a judicial clerk to Judge Herbert L. Chabot of the U.S. Tax Court. Mr. Kadish received his B.A. from Williams College, his J.D. from Case Western Reserve University School of Law, and his LL.M. in taxation from New York University.