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CPE Resources List

Our CPE resources list was designed to serve as a comprehensive repository of information presented in our online tax webinars and seminars. Each link corresponds to key topics covered in our continuing education sessions, offering quick access to critical updates, in-depth guides, expert insight and practical tools. This curated list allows tax professionals to revisit and apply the knowledge gained, ensuring they stay informed and equipped to address complex tax scenarios when needed. It’s a functional extension of our educational offerings, providing value beyond the live sessions.

Files (2025)

2025

Meet JoJo – the Basics AI Assistant
Sample Client Letters & Disclosure Consents

May 2025

May 7 - Calculating DSUE and Gift Taxes on Form 706

Form 706: Filed for estates exceeding the annual estate limit and/or to file the DSUE for the surviving spouse
Form 709: Filed by individuals to report any gifts that surpass the annual gift limit per year
Form 1041: Filed for a trust or estate with income >$600
Used by an executor of a decedent’s estate to calculate and file the estate tax required by Chapter 11 of IRC (if estate exceeds annual exclusion amount)
Also to calculate the generation-skipping transfer tax (GSTT) per Chapter 13 of IRC
Extensions can be filed on Form 4768 for an automatic six-months
Deceased Spouse Unused Exclusion-authorized by IRC Section 2010(c)(4)
Section 2032 – Alternative Valuation
Section 2032a – Special-use Valuation
Section 6166 – Pay Estate Tax In Installments
Section 6163 – Postpone Tax On Reversionary Or Remainder Trust
Section 20.6166-1(d) – Protective Election

May 8 - Related Party Transactions

Related Party Transactions – IRC § 267
Transaction between partners & partnerships – IRC § 707
GSS Holdings (Liberty), Inc v. US, No. 2021-2353 (09/21/2023) ‑ Part of a capital sale
Constructive ownership of stock – IRC § 318
Gain from the sale of depreciable property between related parties – IRC § 1239
Loans between related parties – IRC § 7872
A taxpayer sold shares of stock at a loss to his stepmother in a bona fide transaction – Revenue Ruling 71-50
In determining whether any of these relationships exist, full effect shall be given to a legal adoption see Regs. § 1.267(c)-1(a)(4)
DeBoer v. Commissioner, 194 F.2d 289 (2nd Circuit 1952) – Courts ruled sale is NOT relate party even though Married Filed Joint Return was Filed
Partners in a partnership and the partnership are NOT considered related parties under § 267. These transactions are by § 707 and Regs. § 1.707-1
In the case of a sale or exchange of property, directly or indirectly, between related persons.. Please review IRC § 1239 & Regs. § 1.1239-1 for additional details
Gain from dispositions of certain depreciable realty – § 1250

May 14 - Divorce and its Various Tax Implications

May 16 - Reporting Excess Gift Taxes on Form 709

May 21 - How the IRS Reconstructs Income in Tax Fraud Cases

May 22 - Secure Act 1.0 & 2.0 Hot Topics: Part 1

June 2025

June 3 - Casualty and Theft #1 Introduction for Individual Losses

June 5 - Casualty and Theft #2 Introduction for Business Losses

June 10 - Casualty and Theft Case Study Individual

June 11 - Casualty and Theft Case Study Business

June 17 - Casualty and Theft Odds and Ends

June 19 - Form 1099-MISC and 1099-NEC for 2025

June 24 - Ethics: Part 1

Circular 230 Proposed Regulations – TaxNotes
16 CFR part 314 (2002)
The ethics opinion implicates Model Rule 1.1 (competence), Model Rule 1.4 (communications), Model Rule 1.6 (confidentiality of information), Model Rule 1.15 (safekeeping property), Model Rule 5.1 (responsibilities of a partner or supervisory lawyer) and Model Rule 5.3 (responsibilities regarding nonlawyer assistance)
IRC §7216 is a criminal provision enacted by the U.S. Congress in 197
After a long process that included many public suggestions and comments, updated regulations were published on January 7and July 2, 2008 and apply to uses and disclosures beginning on January 1, 2009
Sample Consent Forms
Form 3949-A Information Referral
Final Treasury Regulations on rules and consent requirement
I RC § 6103 generally prohibits the release of tax information by an IRS employee

June 24 - Ethics: Part 2

Guidance regarding what actions non-practitioners may take in response to IRS inquiries is still necessary and authorized under 31 U.S.C. 330
Proposed regulations would clarify that ERPAs who passed the ERPA-SEE prior to February 12, 2016, remain authorized to practice before the IRS if they continue to pay the annual user fee described under 26 CFR 300.10(b) and complete the continuing education described in § 10.6(e).
Any future user fee will be calculated pursuant to the Independent Offices Appropriation Act of 1952 (31 U.S.C. 9701) and OMB Circular A-25, User Charges
Former IRS employees must apply for special enrollment in accordance with 31 CFR 10.4(d)..
Forms required for renewal may be obtained by sending a written request to the address specified by the Internal Revenue Service or from such other source as the Internal Revenue Service will publish in the Internal Revenue Bulletin (see 26 CFR 601.601(d)(2)(ii)( b)) and on the Internal Revenue Service website

June 26 - Quarterly Tax Update 2025: Part 1

July 2025

July 8 - Ministers/Amish/Mennonite Tax Issues

July 15 - S-Corporation Basis and Form 7203

July 17 - Update on Marijuana Tax Issues

July 22 - Form 706 / 709 Unlock - Estate Planning and Portability

July 24 - Charitable Contributions Compliance

July 29 - Ethics: Part 3

The General Rule under § 7525 – With respect tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney
IRS Publication 1, Your Rights as a Taxpayer, includes a full list of taxpayers’ rights
This includes attorneys, CPAs, enrolled agents, and enrolled actuaries (Joint Committee on Taxation, General Explanation of Tax Legislation Enacted in 1998(JCS-6-98), p. 87 (Nov. 24, 1998))
The federally authorized tax practitioner privilege also does not apply to any communication between a federally authorized tax practitioner and any person, director, officer, employee, agent, or representative of the person, or any other person holding a capital or profits interest in connection with the promotion of the direct or indirect participation in any tax shelter as defined in §. 6662(d)(2)(C)(ii) (§ 7525(b))
Treasury Regulations § 301.7216-2, however, provides for numerous exceptions to this rule

July 29 - Ethics: Part 4

When the representation involves a tax return prepared by a practitioner, the practitioner’s diligence with respect to preparing the tax return would be treated under the proposed regulations as related to the practitioner’s practice before the IRS under 31 U.S.C. 330(a)
Obtain a Power of Attorney Form 2848 for the IRS and a Power of Attorney for the State tax authority
Earnings Record Corrections
Tax Return Exception: If a claimant filed a tax return for self-employment income before the expiration of the time limit, the correction may be made outside the standard time limit
4.12.1.3.1 (10-05-2010) – Management Approval
Review IRM 25.6.1.9.5.3, 25% Omission and IRM 25.6.1.9.5.2, Fraudulent Return
Review IRM 4.10.4.3.2, Minimum Income Probes: “Nonbusiness” Returns
For information concerning the minimum requirements with respect to required filing checks for Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business
Forms such as FinCEN Form 104 Currency Transaction Report (CTR), and FinCEN Form 103 Currency Transaction Report for Casinos (CTR-C), are examined separately as part of the BSA program
TD F 90-22.1, Report of Foreign Bank and Financial Accounts, (FBAR)
See IRM 4.26.8.4, Delinquent BSA Forms, for delinquent Title 31 return acquisition procedures
IRS Privacy Policy for Artificial Intelligence – 09-30-2024 , Control Number: PGLD-10-0924-0020
A client can view their tax records in their Individual Online Account
IRS Online Business Account
Publication 55-B IRS Data Book

July 31 - Employment Taxes and the Trust Fund Recovery Penalty

August 2025

August 6 - Estates & Trusts

August 7 - Ethics: Part 1

Circular 230 Proposed Regulations – TaxNotes
16 CFR part 314 (2002)
The ethics opinion implicates Model Rule 1.1 (competence), Model Rule 1.4 (communications), Model Rule 1.6 (confidentiality of information), Model Rule 1.15 (safekeeping property), Model Rule 5.1 (responsibilities of a partner or supervisory lawyer) and Model Rule 5.3 (responsibilities regarding nonlawyer assistance)
IRC §7216 is a criminal provision enacted by the U.S. Congress in 197
After a long process that included many public suggestions and comments, updated regulations were published on January 7and July 2, 2008 and apply to uses and disclosures beginning on January 1, 2009
Sample Consent Forms
Form 3949-A Information Referral
Final Treasury Regulations on rules and consent requirement
I RC § 6103 generally prohibits the release of tax information by an IRS employee

August 7 - Ethics: Part 2

Guidance regarding what actions non-practitioners may take in response to IRS inquiries is still necessary and authorized under 31 U.S.C. 330
Proposed regulations would clarify that ERPAs who passed the ERPA-SEE prior to February 12, 2016, remain authorized to practice before the IRS if they continue to pay the annual user fee described under 26 CFR 300.10(b) and complete the continuing education described in § 10.6(e).
Any future user fee will be calculated pursuant to the Independent Offices Appropriation Act of 1952 (31 U.S.C. 9701) and OMB Circular A-25, User Charges
Former IRS employees must apply for special enrollment in accordance with 31 CFR 10.4(d)..
Forms required for renewal may be obtained by sending a written request to the address specified by the Internal Revenue Service or from such other source as the Internal Revenue Service will publish in the Internal Revenue Bulletin (see 26 CFR 601.601(d)(2)(ii)( b)) and on the Internal Revenue Service website

August 12 - There is a Form for That – Explore IRS Forms You May Not Know Exist

August 13 - Tax-exempt Organizations

August 14 - IRS issued "B" and "C" Notices - What you need to know & How to fix

August 19 - Impact on Expiring Tax Provisions – TCJA

August 20 - Farm Rentals

August 21 - Quarterly Tax Update 2025: Part 2

August 27 - Residential Complications

August 28 - IRS Streamlined Procedures and the Nonwillful Certification

September 2025

September 3 - Tax Research Strategies

September 9 - Amended vs Superseded Returns

September 17, 19, 23 & 25 - Fall Topical Income Tax Update - SEMINAR

October 2025

October 1 - Fall Topical Income Tax Update - SEMINAR

October 7 - Ethics: Part 3

The General Rule under § 7525 – With respect tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney
IRS Publication 1, Your Rights as a Taxpayer, includes a full list of taxpayers’ rights
This includes attorneys, CPAs, enrolled agents, and enrolled actuaries (Joint Committee on Taxation, General Explanation of Tax Legislation Enacted in 1998(JCS-6-98), p. 87 (Nov. 24, 1998))
The federally authorized tax practitioner privilege also does not apply to any communication between a federally authorized tax practitioner and any person, director, officer, employee, agent, or representative of the person, or any other person holding a capital or profits interest in connection with the promotion of the direct or indirect participation in any tax shelter as defined in §. 6662(d)(2)(C)(ii) (§ 7525(b))
Treasury Regulations § 301.7216-2, however, provides for numerous exceptions to this rule

October 7 - Ethics: Part 4

When the representation involves a tax return prepared by a practitioner, the practitioner’s diligence with respect to preparing the tax return would be treated under the proposed regulations as related to the practitioner’s practice before the IRS under 31 U.S.C. 330(a)
Obtain a Power of Attorney Form 2848 for the IRS and a Power of Attorney for the State tax authority
Earnings Record Corrections
Tax Return Exception: If a claimant filed a tax return for self-employment income before the expiration of the time limit, the correction may be made outside the standard time limit
4.12.1.3.1 (10-05-2010) – Management Approval
Review IRM 25.6.1.9.5.3, 25% Omission and IRM 25.6.1.9.5.2, Fraudulent Return
Review IRM 4.10.4.3.2, Minimum Income Probes: “Nonbusiness” Returns
For information concerning the minimum requirements with respect to required filing checks for Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business
Forms such as FinCEN Form 104 Currency Transaction Report (CTR), and FinCEN Form 103 Currency Transaction Report for Casinos (CTR-C), are examined separately as part of the BSA program
TD F 90-22.1, Report of Foreign Bank and Financial Accounts, (FBAR)
See IRM 4.26.8.4, Delinquent BSA Forms, for delinquent Title 31 return acquisition procedures
IRS Privacy Policy for Artificial Intelligence – 09-30-2024 , Control Number: PGLD-10-0924-0020
A client can view their tax records in their Individual Online Account
IRS Online Business Account
Publication 55-B IRS Data Book

October 9 - Charitable Gifting

October 14 - IRS Collection Due Process Procedures

October 16 - Tax Issues surrounding Sale of Fixed Assets

October 21 - From Summonses to International Evidence Gathering Techniques - How the IRS Gathers Evidence in the 21st Century

October 23 - Form 1041 Compliance Review and Planning: Part 1

October 28 - Form 1041 Compliance Review and Planning: Part 2

October 30 - Turning Theory into Practice - Estates and Trusts

November 2025

November 4 - Clean Vehicle Credits – Purchasing Credits Limitations and Rules

November 6 - Secure Act 1.0 & 2.0 Hot Topics: Part 2

November 11 - Ethics: Part 1

Circular 230 Proposed Regulations – TaxNotes
16 CFR part 314 (2002)
The ethics opinion implicates Model Rule 1.1 (competence), Model Rule 1.4 (communications), Model Rule 1.6 (confidentiality of information), Model Rule 1.15 (safekeeping property), Model Rule 5.1 (responsibilities of a partner or supervisory lawyer) and Model Rule 5.3 (responsibilities regarding nonlawyer assistance)
IRC §7216 is a criminal provision enacted by the U.S. Congress in 197
After a long process that included many public suggestions and comments, updated regulations were published on January 7and July 2, 2008 and apply to uses and disclosures beginning on January 1, 2009
Sample Consent Forms
Form 3949-A Information Referral
Final Treasury Regulations on rules and consent requirement
I RC § 6103 generally prohibits the release of tax information by an IRS employee

November 11 - Ethics: Part 2

Guidance regarding what actions non-practitioners may take in response to IRS inquiries is still necessary and authorized under 31 U.S.C. 330
Proposed regulations would clarify that ERPAs who passed the ERPA-SEE prior to February 12, 2016, remain authorized to practice before the IRS if they continue to pay the annual user fee described under 26 CFR 300.10(b) and complete the continuing education described in § 10.6(e).
Any future user fee will be calculated pursuant to the Independent Offices Appropriation Act of 1952 (31 U.S.C. 9701) and OMB Circular A-25, User Charges
Former IRS employees must apply for special enrollment in accordance with 31 CFR 10.4(d)..
Forms required for renewal may be obtained by sending a written request to the address specified by the Internal Revenue Service or from such other source as the Internal Revenue Service will publish in the Internal Revenue Bulletin (see 26 CFR 601.601(d)(2)(ii)( b)) and on the Internal Revenue Service website

November 13 - Is that Worker an Employee? Questions and Answers on Worker Classification

November 18 - Quarterly Tax Update: Part 3

November 19 - Business Energy Incentives Update

November 20 - Fraud Technical Advisors: An End-Run Around the Case of Tweel?

December 2025

December 2, 5, 9, 10 & 12 - Year-End Federal Tax Update - SEMINAR

December 16 - Quarterly Tax Update: Part 4

December 18 - Ethics: Part 3

The General Rule under § 7525 – With respect tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney
IRS Publication 1, Your Rights as a Taxpayer, includes a full list of taxpayers’ rights
This includes attorneys, CPAs, enrolled agents, and enrolled actuaries (Joint Committee on Taxation, General Explanation of Tax Legislation Enacted in 1998(JCS-6-98), p. 87 (Nov. 24, 1998))
The federally authorized tax practitioner privilege also does not apply to any communication between a federally authorized tax practitioner and any person, director, officer, employee, agent, or representative of the person, or any other person holding a capital or profits interest in connection with the promotion of the direct or indirect participation in any tax shelter as defined in §. 6662(d)(2)(C)(ii) (§ 7525(b))
Treasury Regulations § 301.7216-2, however, provides for numerous exceptions to this rule

December 18 - Ethics: Part 4

When the representation involves a tax return prepared by a practitioner, the practitioner’s diligence with respect to preparing the tax return would be treated under the proposed regulations as related to the practitioner’s practice before the IRS under 31 U.S.C. 330(a)
Obtain a Power of Attorney Form 2848 for the IRS and a Power of Attorney for the State tax authority
Earnings Record Corrections
Tax Return Exception: If a claimant filed a tax return for self-employment income before the expiration of the time limit, the correction may be made outside the standard time limit
4.12.1.3.1 (10-05-2010) – Management Approval
Review IRM 25.6.1.9.5.3, 25% Omission and IRM 25.6.1.9.5.2, Fraudulent Return
Review IRM 4.10.4.3.2, Minimum Income Probes: “Nonbusiness” Returns
For information concerning the minimum requirements with respect to required filing checks for Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business
Forms such as FinCEN Form 104 Currency Transaction Report (CTR), and FinCEN Form 103 Currency Transaction Report for Casinos (CTR-C), are examined separately as part of the BSA program
TD F 90-22.1, Report of Foreign Bank and Financial Accounts, (FBAR)
See IRM 4.26.8.4, Delinquent BSA Forms, for delinquent Title 31 return acquisition procedures
IRS Privacy Policy for Artificial Intelligence – 09-30-2024 , Control Number: PGLD-10-0924-0020
A client can view their tax records in their Individual Online Account
IRS Online Business Account
Publication 55-B IRS Data Book

Files (2024)

2024

Basics & Beyond Year-End Seminar: Group Sign-In Sheet
Hightail Year-End Materials
Circular 230 (PDF)
Sample Engagement Letter for 2023 Individual Tax Preparation
CTA and BOI Resource Material – Word doc
Combined CTA BOI Resource Information – Information PDF
- 12/5/24 – Texas Court Blocks CTA Enforcement (PDF – 12.05.24 AICPA Special on BOI Reporting Halt)
- 12/23/24 – The U.S. Court of Appeals for the Fifth Circuit overturned the BOI injunction.
Written Information Security Plan “WISP” (Pub 5708)
2024 Drake Reference Guide
Sample Partnership Abatement Letter (84-35 letter)
Sample Request for FTA Letter (FTA Example)

May 2024

May 22 - Hobby Losses

May 23 - Quarterly Tax Update 2024: Part 1

June 2024

June 6 - The Basics of LLC’s

June 13 - Ethics Part 1

Form 14242, Report Suspected Abusive Tax Promotions or Preparers contains a questionnaire that should be used to record informant contacts and to facilitate referrals to the:
Internal Revenue Service Abusive Schemes Lead Development Center. Online referrals can also be made using the Form 14242, Document Upload Tool
Considerations for IRS Examinations of ERC Claims

June 13 - Ethics: Part 2

June 19 - Overview of Form 1040 & Tax Change Basics for 2024

June 21 - Anatomy of a Civil Tax Controversy

June 26 - Wealth Transfer Tax Strategies

July 2024

July 9 - Ethics: Part 3

July 9 - Ethics: Part 4

July 11 - Understanding LLCs and Entity Classifications

July 17 - The Kovel Accountant

July 18 - SECURE 1.0 and 2.0 Acts

July 24 - Filing DSUE & Form 706

July 25 - Form 1099K Payment Card & 3rd Party Transactions

July 31 - Charitable Gift Strategies

August 2024

August 8 - The DNA of Schedule C

August 13 - Short Term Rentals

August 14 - Popular Tax Breaks and Deductions

August 15 - 1031 Exchanges

IRS Publication (2023) – Sales and other dispositions of assets
Section 1031
Form 8824 Like-Kind Exchanges

August 20 - Quarterly Tax Update (2024): Part 2

IRS ERC Withdrawal Program
IRS claim withdrawal process
National Taxpayer Advocate, Erin Collins, mid-year report to Congress
Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government
Social Security to Expand Access to SSI Program by Updating Definition of a Public Assistance Household
Social Security to Remove Barriers to Accessing SSI Payments
Social Security to Expand SSI Rental Subsidy Policy
National Taxpayer Advocate’s 2023 Annual Report to Congress
Taxpayer Advocate Service’s (TAS’s) plans to increase awareness of the risks related to the lack of federal oversight for paid return preparers.
IRS Cannabis industry FAQs
IRS Cannabis industry other information
IRS announced a new effort focused on high-income taxpayers
IRS announced a new series of steps to combat abusive partnership transactions
IRS announced plans to begin dozens of audits involving personal use of business aircraft
The transferability provisions of the Inflation Reduction Act
IRS has warned taxpayers not to fall for scams (Fuel Tax Credit, Sick and Family Leave Credit, etc.)
IRS FAQs on Tax Credits for Paid Leave
Form 14242 – Report Suspected Abusive Tax Promotions or Preparers

August 21 - Updated Retirement Contributions & Distributions

August 22 - Ethics: Part 1

August 22 - Ethics: Part 2

September 2024

September 10 - Ethics: Part 3

Annual Filing Season Program CPE Requirements

September 10 - Ethics: Part 4

Guidance on Restrictions during suspension or disbarment from practice
About Form 8821, Tax Information Authorization

September 11 - Taking off the gloves: What to Expect in US Tax Court

September 18, 20, 24 & 26 - Fall Topical Income Tax Update - SEMINAR

#1 - Overview New Tax Laws & Updates:

Notice 2022-53
Notice 2023-54
IRS definitions: primary residence
Frequently asked questions about energy efficient home improvements and residential clean energy property credits
Energy Star requirements
The home energy audit must:
Department of Energy certification programs for the Energy Efficient Home Improvement Credit (§ 25C)
Notice 2023-59
qualify through other efficiency criteria
Notice 2013-70, IRB 2013-47
Publication 5866, New Clean Vehicle Tax Credit Checklist
Publication 5905, Information for Consumers Purchasing a New or Used Clean Vehicle
Find information on credits for used clean vehicles
Find information on credits for qualified commercial clean vehicles
Find information on credits for new plug-in EVs purchased before 2023

#2 - Other Tax Law Topics:

Notice 2014-7
See Stromme v. Commissioner, 138 T.C. 213, 218 (2012), citing Dobra v. Commissioner, 111 T.C. 339 (1998)
Medicare Waiver Payments
Tax Exempt Organization Search list – IRS
Streamline Retroactive Revocation Process – IRS
Form 1023, Form 1023-EZ, Form 1024 or Form 1024-A with appropriate user fee
Form 1120, U.S. Corporation Income Tax Return within tax year
Form 1041, U.S. Income Tax Return for Estates and Trusts within tax year
Publication 78
FAQs – Automatic revocation of exemption for non-filing
Flora v. United States, 362 U.S. 145
Rev. Rul. 2004-34, Rev. Rul. 2006-17, Shultz v. IRS, Rev. Rul. 2004-29
The IRS has created a special withdrawal program for those with pending claims
It is important for taxpayers to understand why they received a Form 1099-K, then use the form
if they received a Form 1099-K but shouldn’t have
Notice 2023-74
Form 1099-K, Payment Card and Third-Party Network Transactions
offer in compromise
Form 13711, Request for Appeal of Offer in Compromise
send a letter to the IRS with certain information about their situation
Form 656, Offer in Compromise
Form 433-B (OIC), Collection Information Statement for Businesses
Form 433-A (OIC), Collection Information Statement for Wage Earners and Self-Employed Individuals
Administration’s proposed FY 2025 budget
Rev. Proc. 2024-28 – Allocate Basis in Digital Assets
IRS Static Files Directory

#3 - Form 709 - Gift Tax Return:

#4 - IRS Fall Notices 2024:

Small Business toolkit – FinCEN
FinCEN BIO-FAQs
Letter 6173 – Virtual Currency
Notice CP25T – Adjustment of Estimated Tax Payments
Notice CP40 – Assignment to Collection Agency
Notice CP561C – Child’s Expired ATIN
Notice CP563 – Child’s Expired ATIN
Notice CP59 – Non-Filer Notice
Notice CP16T – Changes to Return (Overpayment or Error)
Letter 6018-B – Confirming Representation
Letter 6018 – Confirming Representation
Notice CP523H – Termination of Installment Agreement
Forms and Publications about appeal rights
Form 9423 – Collection Appeal Request
Form 2848 – Power of Attorney
Notice CP14I – RMD not Taken
Notice CP48 – Renew ITIN
Notice CP291 – Termination of a ESBT
Notice CP45 – Overpayment Not Applied
Letter 2531 – Matching Notice
Letter 2030 – Matching Notice
Notice CP01S with Form 14039
Notice CP301 – Client Accessing IRS Account
Notice CP08 – Additional Child Tax Credit
Notice CP53 – Cannot Honor Direct Deposit
Notice CP153 – Cannot Direct Deposit Refund
Notice CP53B – Cannot Direct Deposit Refund
Notice CP248 – Must Make Federal Tax Deposits Electronically
Notice CP148A – Notice of Change of Address
Notice CP148B – Notice of Change of Address
Notice CP508C – Passport Notification
Notice CP508R – Passport Notification
Notice CP238 – No Penalty for Late FTD Payments
Notice CP235 – Change in Deposit Requirements
Notice CP60 – Misapplied Payment
Notice CP231 – Refund Returned to IRS
Notice CP547 – CAF Number Assigned
Notice CP264 – S Election Not Approved
Notice CP279 – Parent S Corporation Election Accepted
Notice CP261 – S Corporation Election Accepted
Notice CP91 – Levy Notification (SS Benefits)
Notice CP3219N – Notice of Deficiency
Guidance for Petitioners: Starting a Case
Notice CP79B – Denial of Credits
Notice CP01H – Deceased Individual (Filed – Lock Notification)
Notice LP60 – Information Requested for a Deceased Taxpayer
Notice CP39 – Application of Overpayment
Notice CP259 – Client Failed to File Form 941
Notice CP04 – Military Dates of Service
IRS Static File Directory
Clean Vehicle Credits
Notice CP504B – “Wake up Call”
Notice CP51A – Language

#5 - Ethics for the Tax Professional:

Circular 230 – IRS
G20 Public Trust in Tax Survey

#6 - Keeping Client Data Secure:

Template – Start a Security Plan
Safeguarding Taxpayer Data – IRS Pub. 4557
Complete Checklist – Data Theft Information for Tax Professionals
IRS Stakeholder Liaison local contacts

Additional Speaker Links:

Processing Status for tax forms – IRS
Section 9 – Notices and Notice Codes
IR-2024-203 – IRS moves forward with Employee Retention Credit claims
Understanding Letter 105 C – Disallowance of the Employee Retention Credit
Earned Income Tax Credit (EITC) Assistant – IRS
Forms 886 Can Assist You

October 2024

October 2 - Fall Topical Income Tax Update – SEMINAR

#1 – Overview New Tax Laws & Updates:

Notice 2022-53
Notice 2023-54
IRS definitions: primary residence
Frequently asked questions about energy efficient home improvements and residential clean energy property credits
Energy Star requirements
The home energy audit must:
Department of Energy certification programs for the Energy Efficient Home Improvement Credit (§ 25C)
Notice 2023-59
qualify through other efficiency criteria
Notice 2013-70, IRB 2013-47
Publication 5866, New Clean Vehicle Tax Credit Checklist
Publication 5905, Information for Consumers Purchasing a New or Used Clean Vehicle
Find information on credits for used clean vehicles
Find information on credits for qualified commercial clean vehicles
Find information on credits for new plug-in EVs purchased before 2023

#2 – Other Tax Law Topics:

Notice 2014-7
See Stromme v. Commissioner, 138 T.C. 213, 218 (2012), citing Dobra v. Commissioner, 111 T.C. 339 (1998)
Medicare Waiver Payments
Tax Exempt Organization Search list – IRS
Streamline Retroactive Revocation Process – IRS
Form 1023, Form 1023-EZ, Form 1024 or Form 1024-A with appropriate user fee
Form 1120, U.S. Corporation Income Tax Return within tax year
Form 1041, U.S. Income Tax Return for Estates and Trusts within tax year
Publication 78
FAQs – Automatic revocation of exemption for non-filing
Flora v. United States, 362 U.S. 145
Rev. Rul. 2004-34, Rev. Rul. 2006-17, Shultz v. IRS, Rev. Rul. 2004-29
The IRS has created a special withdrawal program for those with pending claims
It is important for taxpayers to understand why they received a Form 1099-K, then use the form
if they received a Form 1099-K but shouldn’t have
Notice 2023-74
Form 1099-K, Payment Card and Third-Party Network Transactions
offer in compromise
Form 13711, Request for Appeal of Offer in Compromise
send a letter to the IRS with certain information about their situation
Form 656, Offer in Compromise
Form 433-B (OIC), Collection Information Statement for Businesses
Form 433-A (OIC), Collection Information Statement for Wage Earners and Self-Employed Individuals
Administration’s proposed FY 2025 budget
Rev. Proc. 2024-28 – Allocate Basis in Digital Assets
IRS Static Files Directory
Section 9 – Notices and Notice Codes

#3 – Form 709 – Gift Tax Return:

#4 – IRS Fall Notices 2024:

Small Business toolkit – FinCEN
FinCEN BIO-FAQs
Letter 6173 – Virtual Currency
Notice CP25T – Adjustment of Estimated Tax Payments
Notice CP40 – Assignment to Collection Agency
Notice CP561C – Child’s Expired ATIN
Notice CP563 – Child’s Expired ATIN
Notice CP59 – Non-Filer Notice
Notice CP16T – Changes to Return (Overpayment or Error)
Letter 6018-B – Confirming Representation
Letter 6018 – Confirming Representation
Notice CP523H – Termination of Installment Agreement
Forms and Publications about appeal rights
Form 9423 – Collection Appeal Request
Form 2848 – Power of Attorney
Notice CP14I – RMD not Taken
Notice CP48 – Renew ITIN
Notice CP291 – Termination of a ESBT
Notice CP45 – Overpayment Not Applied
Letter 2531 – Matching Notice
Letter 2030 – Matching Notice
Notice CP01S with Form 14039
Notice CP301 – Client Accessing IRS Account
Notice CP08 – Additional Child Tax Credit
Notice CP53 – Cannot Honor Direct Deposit
Notice CP153 – Cannot Direct Deposit Refund
Notice CP53B – Cannot Direct Deposit Refund
Notice CP248 – Must Make Federal Tax Deposits Electronically
Notice CP148A – Notice of Change of Address
Notice CP148B – Notice of Change of Address
Notice CP508C – Passport Notification
Notice CP508R – Passport Notification
Notice CP238 – No Penalty for Late FTD Payments
Notice CP235 – Change in Deposit Requirements
Notice CP60 – Misapplied Payment
Notice CP231 – Refund Returned to IRS
Notice CP547 – CAF Number Assigned
Notice CP264 – S Election Not Approved
Notice CP279 – Parent S Corporation Election Accepted
Notice CP261 – S Corporation Election Accepted
Notice CP91 – Levy Notification (SS Benefits)
Notice CP3219N – Notice of Deficiency
Guidance for Petitioners: Starting a Case
Notice CP79B – Denial of Credits
Notice CP01H – Deceased Individual (Filed – Lock Notification)
Notice LP60 – Information Requested for a Deceased Taxpayer
Notice CP39 – Application of Overpayment
Notice CP259 – Client Failed to File Form 941
Notice CP04 – Military Dates of Service
IRS Static File Directory
Clean Vehicle Credits
Notice CP504B – “Wake up Call”
Notice CP51A – Language

#5 – Ethics for the Tax Professional:

Circular 230 – IRS
G20 Public Trust in Tax Survey

#6 – Keeping Client Data Secure:

Template – Start a Security Plan
Safeguarding Taxpayer Data – IRS Pub. 4557
Complete Checklist – Data Theft Information for Tax Professionals
IRS Stakeholder Liaison local contacts

Additional Speaker Links:

Processing Status for tax forms – IRS
Section 9 – Notices and Notice Codes
IR-2024-203 – IRS moves forward with Employee Retention Credit claims
Understanding Letter 105 C – Disallowance of the Employee Retention Credit
Earned Income Tax Credit (EITC) Assistant – IRS
Forms 886 Can Assist You
Form 7217 Draft – Partner’s Report of Property Distributed by a Partnership

October 8 - Ethics: Part 1

Form 14242, Report Suspected Abusive Tax Promotions or Preparers contains a questionnaire that should be used to record informant contacts and to facilitate referrals to the:
Internal Revenue Service Abusive Schemes Lead Development Center. Online referrals can also be made using the Form 14242, Document Upload Tool
Considerations for IRS Examinations of ERC Claims
Guidance on the Employee Retention Credit under Section 3134
Form 15434 – Application for Second Employee Retention Credit (ERC) Voluntary Disclosure Program – IRS (Tax Institute link – in case of PDF reading error)

October 8 - Ethics: Part 2

October 9 - Gift Tax Reporting on Form 709

Form 709 – IRS
Publication 551, Basis of Assets – IRS

October 16 - The Fifth Amendment & Offshore Audits

Act of Producing Documents in Response to a Subpoena (Fisher v. United States, 425 U.S. 391 (1976))
United States v. Hubbell, 530 U.S. 27 (2000) – Whitewater case
Privilege applies only to compelled testimony (Couch v. United States, 409 U.S. 322 (1973))
Braswell v. United States, 487 U.S. 99 (1988)
FinCEN Form 114
United States v. Greenfield, No. 15-543 (2d Cir. 2016) narrowed the scope of the required records production.

October 17 - Employee vs Independent Contractor

October 23 - Tax Implications of the Gig Economy

Notice 2023 – 10 – IRS
IRS announces delay in Form 1099-K reporting threshold for third party platform payments in 2023
Notice 2024 – 74 – IRS
Gig Economy tax center
Important Tax Guidelines for Online Crowdfunding
Tax Time Guide (March 2024): Reporting Digital Asset Transactions, Gig Economy Income, Foreign Source Income and Assets
Hobby vs. Business
Info to Help Gig Economy Workers w/their Tax Responsibilities
Understanding your form 1099-K
What to do with Form 1099-K
IRS Form 1099-K Myths vs Facts

October 24 - Hobby Loss

October 30 - Overview of Form 1040

Form 1040 – 2023
New 2024 Tax Brackets
Disaster Tax Relief Information & Resources
Earned Income Tax Credit
Tax Reform
Fact Sheets
IRS Current Tax Tips
IRS Guidance
Bonus Section
- Secure 2.0 developments and guidance for 2024
- Major tax changes in 2026
- Tax planning for the TCJA’s sunset
- Revenue Procedure 2024-31
- Energy Efficient Home Improvement Credit (EEHIC)
- Pub. 5967 – Energy Efficient Home Improvement Credit (25C)
- Pub. 5976 – How to claim an EEHIC residential energy property
- Pub. 5978 – How to claim an EEHIC home energy audit
- Pub. 5979 – How to claim an EEHIC exterior doors, windows
- Fast Facts & Figures about Social Security (2024)
- Social Security OACT Facts (6/24)
- Social Security Fact Sheet – Important for Women
- Taxpayer Data Protection Act (HR 8292)
- Chronic Disease Flexible Coverage Act (HR 3800)
- VSO Equal Tax Treatment (VETT) Act (HR 1432)
- Social Security Fairness Act (HR 82)

October 31 - Trusts and Estates: Part 1

IRS Publication 559
Form 56 – Notice Concerning Fiduciary Relationship
Structure of IRC Subchapter J – Part I & II
USC 6012 – Persons required to make returns of income
Power of Appointment – IRC 2041
Wandry v. Commission (TC Memo 2012-88)
Three Tax Court cases approving the Wandry strategy. Christiansen (8th Circuit); Petter (9th Circuit); and Hendrix (5th Circuit)
Trust is valid under state law (Treas Regs §1.401(a)(9)-4, Q&A 5(b)(1))
IRC 643 – Distributable Net Income
Treas Regs §1.643(a)-3(b)
“65-day rule” – IRC §663(b)(1)
Treas. Regs §1.663(c)-5
Form 8855 – Election To Treat a Qualified Revocable Trust as Part of an Estate

November 2024

November 6 - Trusts and Estates: Part 2

IRC §67(g) – Effect on Trusts & Estates
Treas Regs §1.642(h)-2
Treas Regs §1.652(b)-3
IRC §642(h)(2)
IRC §67(e) – Determination of adjusted gross income in case of trusts & estates
IRC §62(a)(4) – Adj gross income defined
Schedule K-1 (Form 1041)
IRC §172(b)(3) – FAQs on carrybacks of NOLs
IRC §691 – Income with respect of a decedent
IRC §643(e) – Election to recognize gain/loss
IRC §673 – Reversionary interests
IRC §674 – Power to control beneficial enjoyment
IRC §675 – Administrative powers
IRC §676 – Power to revoke
IRC §677 – Income for benefit of grantor
IRC §678 – Person other than grantor treated as substantial owner
IRC §679 – Foreign trusts having one or more United States beneficiaries
Fiduciary Accounting Income (Treas. Regs. §1.671-2(b))
IRC §4947(a)(1) – General Explanation of Trusts
Form 1041 (2023)
IRC Sec. 642(g) and Regulation 1.642(g)-1
IRC Sec. 2053 – Deduction of interest expense
CRTs in Rev Proc 2003-53 through Rev Proc 2003-60 (CRAT)
Treas Regs §1.664-2(b)
the IRC §7520 interest rates
DSUE Portability Relief under Revenue Procedure 2022-32 supersedes simplified late election under Rev. Proc. 2017-34

November 7 - Understanding Financial Statements for Schedule C’s, S Corps & Partnerships

Statement of Equity: Owner’s Equity (Sch C), Partner Equity (1065), Shareholder Equity (1120S)
Section 179 Deduction – Special Depreciation Allowance • MACRS • Listed Property

November 12 - Ethics: Part 3

Annual Filing Season Program CPE Requirements

November 12 - Ethics: Part 4

Form 2848
Review Circular 230, § 10.61(b)(1) – Voluntary sanction
Review Circular 230, § 10.50 – Sanctions
Review Circular 230, Sections 10.60-10.76 – Rules applicable to Disciplinary Proceedings
Guidance on Restrictions during suspension or disbarment from practice
About Form 8821, Tax Information Authorization
Review Circular 230, Section 10.77 – Appeal of decision of Administrative Law Judge
§ 6700 – Promoting abusive tax shelters
§ 6701 – Aiding and abetting understatement of a tax liability
§ 7407 – Injunction of a tax return preparer
§ 7408 – Injunction for specified conduct relating to tax shelters
§ 6662 – Accuracy related penalty
§ 6694(a) – Understatement of liability due to an unreasonable position
§ 6695 – (a) Failure to furnish copy of return
§ 6702 – Frivolous tax returns or submissions

November 13 - Various Form 1099s

Form 1099-DA
Form 1099-NEC
Form 1099-MISC
Form 1099-R
Form 1099-SA
Form 1099-DIV
Form 1099-INT
Form 1099-B
Form 1099-A
Form 1099-C
Form 1099-G
Form 1099-LTC
Form 1099-OID
Form 1099-PATR
Form 1099-Q
Form 1099-S
Revised Timeline Regarding Implementation of Amended Section 6050W(e) – Notice 2023-10
IRS announces delay in Form 1099-K reporting
Form 1099-K
About General Instructions for Certain Information Returns

November 14 - Quarterly Tax Update 2024: Part 3

HR 190 – Saving Gig Economy Taxpayers Act.
SECURE 2.0 developments and guidance for 2024
Major tax changes in 2026
Tax planning for the TCJA’s sunset
Revenue Procedure 2024-31 and proposed regulations to provide guidance for the Energy Efficient Home Improvement Credit
Publication 5967, Energy Efficient Home Improvement Credit (25C)
Publication 5976, How to claim an Energy Efficient Home Improvement tax credit residential energy property
Publication 5978, How to claim an Energy Efficient Home Improvement tax credit home energy audit
Publication 5979, How to claim an Energy Efficient Home Improvement tax credit exterior doors, windows, skylights and insulation materials
Letter to DOJ to investigate tax preparation companies
TIGTA audit report (Sept 24)
Form W-12, IRS Paid Preparer Tax Identification Number (PTIN) Application and Renewal with instructions PDF
Various tax scams claiming their tax refund
Trump Tax Plan ideas (TaxFoundation.org)
Social Security Fast Facts & Figures
Social Security Program Fact Sheet
Social Security is important to Women
States sending tax rebate, ‘stimulus checks‘
Taxpayer Data Protection Act ( H.R.8292 )
Chronic Disease Flexible Coverage Act ( H.R. 3800
VSO Equal Tax Treatment (VETT) Act ( H.R. 1432
Social Security Fairness Act ( H.R. 82 )

November 19 - S Corp Basis (Form 7203) and Partnership Basis

Form 6198 (PDF) – At-Risk Limitations
Schedule K-1 (Form 1120-S)
Form 7217 – Partner’s Report of Property Distributed by Partnership
IRC Regulation 1.1367-1(g)
§ 1.1367-1(g) election – IRS Publication
Determining basis of Partnership Interests – § 1.705-1

November 20 - Demystifying the FBAR

Cook v. Tait, 265 U.S. 47 (1924)
Bank Secrecy Act
Duck Test for the FBAR
26 U.S.C. § 7701(b) – Residency Test
(Hom, 45 F. Supp. 3d 175 (N.D. Cal. 2014)
31 C.F.R. Section 103.24
31 U.S.C. Section 5312(a)(2)(R)
Form 114a, Record of Authorization to Electronically File FBARs
Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
United States v. Bussey, 942 F.2d 1241, 1428 (8th Cir. 1992)
Form TD F 90-22.1 [FBAR]
IRC § 6048, IRC § 6039F
Form 926, IRC § 6038B
Form 3520-A, IRC § 6048(b)
Form 5471, IRC § 6035, IRC § 6046
Form 5472
Form 8865
Form 8938
Moore v. United States

November 21 - SECURE 1.0 and 2.0 Acts

SECURE 1.0 – §201
Dept. of Labor – Form 5500 Series
Final RMD Regulations
10-Year RMD Rule Background
SECURE Act 1.0 §§ 114 and 401
Year of Death RMDs
SECURE 2.0 – §307
IRC §170(f)
Pension Protection Act
SECURE 2.0 – §332
IRC §72(t)(6)(B)
IRC §408(d)(3)(G)
IRC §408(p)(11)(B)
SECURE 2.0 – §126
IRC §529
SECURE 2.0 – §102
Form 8881 – Credit for Small Employer Pension Plan startup
SECURE 2.0 – §109
SECURE 2.0 – §327

December 2024

December 3, 6, 10, 11, & 13 - Year-End Federal Tax Update - SEMINAR

#1 - Federal Tax Law Updates, CTA updates, RMDs, Estates and Trusts

Revenue Procedure 2024-40
§ 179 maximum deduction
First-Time Abatement Program
FTA Case Law:
- Moore v. U.S., No. 22-800 (Decided June 20, 2024)
- Loper Bright Enterprises v. Raimondo (No. 22-451, U.S. June 28, 2024)
- Chevron Doctrine (Chevron USA, Inc v. Natural Resources Defense Council, 1984 Supreme Court Case)
- Betty Amos vs. Commissioner of IRS, US Tax Court 4331-18
- Jurries , TC Summary Opinion 2024-6, May 22, 2024
- Wayne Lee vs. US of America, 11th Circuit, No. 22-10793 (October 24, 2023)
- Wright v. Commissioner of Internal Revenue, T.C. Summary Opinion 2024-9 (June 10, 2024)
- Texas Court Blocks CTA Enforcement (PDF – 12.05.24 AICPA Special on BOI Reporting Halt)
DEA reclassifying marijuana IR 2024-177
IR 2024-65 – Beware of companies misrepresenting nutrition, wellness and general health expenses
Case Law:
- National Small Business United v. Yellen
- Gargasz v. Yellen (Ohio)
- Boyle v. Yellen (Maine)
- Small Business Association of Michigan v. Yellen (Michigan)
- Texas Top Copy Shop v. Garland (Texas)
- Black Economic Council of Massachusetts, Inc. v. Yellen (Massachusetts)
- Firestone et al v. Yellen (Oregon)
- Taylor v. Yellen (Utah)
- Community Associations Institute, et al v. Janet Hellen (Virginia)
Final RMD Regulations
10-Year RMD Rule Background
SECURE Act 1.0 §§ 114 and 401
“Year of Death” RMDs
Charitable documentation requirements – IRC §170(f)
Pension Protection Act
SECURE 2.0 – §126
Limited IRC §529 Plan Transfers to ROTH IRA
SECURE 2.0 – §109
SECURE 2.0 – §327
Rev. Proc. 2017-34
Revenue Procedure 2022-32
Form 706
Elect Portability Under IRC §2010(c)(5)(A)
IRC §6511(a)
IRC §645
IRC §1014(f)
IRC §6035
IRC §2053
TD 9991 Final Regulation
IRS Notice 2024-54
REG-124593-23, 89 Fed. Reg. 51476
Revenue Ruling 2024-14
Revenue Ruling 2023-2
Landmark transferee liability decision – Estate of Paulson (68 F.4th 528 (9th Cir. 2023))
Life insurance valuation issues – DeMatteo (No. 3634-21 (T.C. 2/22/24 – stipulated decision)
Connelly, Executor of Estate Connelly v. US, Supreme Court No 23-146 (June 6, 2024)
CCA 202352018
Estate of Anenberg (162 T.C. No. 9 (2024))

#2 - S Corporation (Form 7203) and Partnership Basis & BBA Issues

Regulations § 1.752-1(a)(4)
Form 6198 – At-Risk Limitations
Schedule K-1 (Form 1120-S)
IRC Regulation 1.1367-1(g)
§ 1.1367-1(g) election – The Tax Advisor

#3 - Overview of Virtual Currency (Form 1099-DA)

12/5/24 UPDATED FORM – Form 1099-DA
Digital Token Identifier (Registry Search)
Blockchain Explorer (website) – used to establish FMV of the asset at a specific date/time.
IRS Notice 2023-27
About IRS Written Determinations
CCA 202035011
CCA 202114020
CCA 202124008
CCA 202302011
CCA 202302012
CCA 202316008
TD 10000
IRS Memorandum #202302012
Treas Regs §1.170A-17
Rev Proc 2024-28, 2024-31 IRB 1
FinCEN Notice 2020-2
Report of Cash Payments over $10k – Form 8300
Notice 2024-56
Notice 2024-57

#4 - Tax Implications of House Flipping

#5 - Ethics

Written Information Security Plan “WISP” (Pub 5708)
How to create a WISP (Pub 5709)
Safeguarding Taxpayer Data (Pub 4557)
ABA Formal Ethics Opinion 483
Code of Professional Conduct ET 1.700.001
AICPA Statements on Standards for Tax Services No. 1.3
(NAEA) Code of Ethics 4
IRS Information Center (§ 7216)
Treasury Circular No. 230
Health Information Privacy
NATP’s Standards of Practice

#6 - Prepare Your Client for 2025, Ask the Expert

Residential Energy Credits (Form 5695)
Application for Employer Identification Number (Form SS-4)
New Guide to business expense resources (IRS Publication) – old Publication 535
New Form 7217 – Partner’s Report of Property Distributed by a Partnership
Once the § 732 basis rules come into play, there may still be unanticipated complications in the form of § 732(d)
Don’t forget the Mandatory Application of § 732(d)

December 17 - Penalty Abatement

Agenda:
- Revenue Procedure 84-35
- Form 843
- Forms 8275 & 8275-R
Penalty Administration:
- IRM 20.1.1.2.2 (11-25-2011)
Reasonable Cause:
- IRM 20.1.1.3.6 (10-19-2020)
FTA:
- IRM 20.1.1.3.3.2.1 (10-19-2020)
- Administrative Waiver (20.1.1.3.3.2)(08/05/2014)
Criteria for Relief:
- IRM 20.1.1.3 (10-19-2020)
- IRM 20.1.1.3 (10-19-2020)
§10.34 – Standards with Respect to Tax Returns
Wells Fargo & Company, 119AFTR 2d 2017-1976 (DC MN 2017)
Reasonable Cause:
- IRM 20.1.1.3.2 (11-21-2017) – Exercise ordinary business care
- IRM 20.1.1.3.2.2 (02-22-2008) – Ordinary Business Care
- Simonsen (2018) – “Good Faith” on behalf of taxpayers
- IRM 20.1.1.3.2.2.1 (11-25-2011) – Death, Serious Illness
- IRM 20.1.1.3.2.2.2 (10-19-2020) & IRM 20.1.1.3.3.5 (10-19-2020) – Fire, Casualty
- IRM 20.1.1.3.2.2.3 (12-11-2009) – Unable to obtain records
- IRM 20.1.1.3.2.2.4 (12-11-2009) – Mistake was made
- IRM 20.1.1.3.2.2.5 (11-21-2017) – Erroneous Advice
- IRM 20.1.1.3.2.2.6 (11-25-2011) – Ignorance of the law
- IRM 20.1.1.3.3.3 (08-05-2014) – Undue Hardship
- IRM 20.1.1.3.3.4 (08-05-2014) – Advice
- Written Advice form the IRS – IRM 20.1.1.3.3.4.1 (11-25-2011)
- Oral Advice form the IRS – IRM 20.1.1.3.3.4.2 (12-11-2009)
- Advice from a Tax Advisor – IRM 20.1.1.3.3.4.3 (11-21-2017)
- Subsequent Requests for Penalty Relief – IRM 20.1.1.3.5.1 (10-19-2020)
- Treasury Regulations 1.6664-4
Authorities:
- IRM 20.1.1.1.2 (10-19-2020)
- IRC § 6662
- IRC § 6662A
- Regs 1.6662-1 through 1.6662-7
- Regs 1.6664-4
- IRM 20.1.1.3.2
§6651(a)(1) – Failure to File
§6651(a)(2) – Failure to Pay
§6721 – Failure to File Correct Information Reporting Returns
§6722 – Failure to File Furnish Correct Payee Statements
§6723 – Failure to comply with Other Information Reporting
Accuracy-Related Penalties – Treas. Reg. §1.6664-4
Failure to File a Tax Return and/or Failure to Pay tax penalties – Treas. Reg. §301.6651-1(c)
Failure to Deposit Penalty – Treas. Reg. §301.6656-1(b); Treasury Decision 8947
Information Return Penalties – Treas. Reg. §301.6723-1(A)(d) & Treas. Reg. §301-6724-1
Prepare/Promoter Penalties – Treas. Reg. §1.6694-2(e)(1)-(6) & Treas. Reg. §301.6707-1T Q&A (4)
Resources:
- Treas. Reg. 301.6724-1 – Reasonable Cause
- IRC 6724 – Waiver; Definitions and Special Rules
- IRM 20.1.1 – Introduction and Penalty Relief
- IRM 20.1.5 – Return Related Penalties
- IRC 6662 -Imposition of Accuracy-related Penalty on Underpayments
- Treasury Regulations §301.6651-1 – Showing of Reasonable Cause in FTF and FTP situations
IRM 20.1.2.2.4.1 (07-18-2016) – late filing and paying taxpayer
Regulations §301.6651-1(c) – Failure to Pay
Case Law:
- Supreme Court – United States v. Boyle, 469 U.S. 241 (1985)
- Intress v. United States, Dkt. No. 3:18-cv-00851 (M.D. Tenn. 2019)
- Wayne Lee vs. US of America, 11th Circuit, No. 22-10793 (October 24, 2023)
- Elstein v. Commissioner, T.C. Summary 2022-14
- Tracy, TC Summ . Op. 2023-30
- Corbin & Dorice McNeill V. Comm., Wyoming DC, 14-CV-172-F, Feb 24, 2017
Penalty under IRC § 6698 for Late Filing of Partnership Tax Return Relief.
Used by taxpayers and tax return preparers to disclose items or positions (Form 8275), and those taken contrary to a regulation (Form 8275-R)

December 18 - Ethics: Part 1

Tax Gap – Publication 5869 – The Effect of Information Reporting on Tax Compliance
OPR Issue 2023-02 – Professional Responsibility and the ERC
Diligence as to Accuracy § 10.22(a) of Circular 230
For purposes of exercising due diligence, § 10.34(d) allows a practitioner to generally rely in good faith and without verification..
..the practitioner must, under § 10.21, promptly inform the client of the noncompliance, error..
Unreasonable Position – §6662 (d)(2)(B)(ii)(I)
..a practitioner must also inform the client of any opportunity to avoid penalties through adequate disclosure by, for example, filing Form 8275, Disclosure Statement..
Written Advice.. a related provision- § 10.37(a)(3) concerning written advice provided by a practitioner
Form 14242, Report Suspected Abusive Tax Promotions or Preparers contains a questionnaire that should be used to record informant contacts and to facilitate referrals to the:
Internal Revenue Service Abusive Schemes Lead Development Center. Online referrals can also be made using the Form 14242, Document Upload Tool
Consideration for IRS Examinations of ERC Claims

December 18 - Ethics: Part 2

Due Diligence § 10.22 – All tax preparers are required to exercise due diligence.
Form 13614-C – Intake/Interview and Quality Review Sheet
NEW – IP Pin for 2025 Tax Filing Season

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