Defensive Tax Practice and IRS Publication 230 WEBCAST - Partnered with the Oregon Society

Overview

Today, tax related issues constitute over 50% of all claims asserted against CPAs. Thi course includes most aspects of a professional’s tax practice under IRC 6694; planning, return preparation, and audit representation. It covers three major subjects: first, client consulting tax advance transaction planning, structuring, and coordinating; second, preparation of and “preparer” signature on the actual federal tax return to be filed; and third, representing the client during an audit by an IRS revenue agent and/or at IRS appeals. The professional’s roles here and ethical positions may significantly change. The degree of responsibility and related potential damages asserted by both the client and taxing authorities against the CPA preparer are explored.

Many tax-related legal reported cases are referred to in this course to provide substantive examples of the application of a given IRS legal principle to practitioner’s client tax factual situations. Case citations are included so you can read the actual case holdings; Google the citation. Unless the legal decision is from the U.S. Supreme Court there is no certainty that the tribunal of any individual state, U.S. Tax Court, or federal Circuit Court of Appeals would follow the cited precedent. State Supreme court decisions control their state courts and State Board of Accountancy, but not IRS. Federal Court of Appeals decisions control their district trial courts.

Highlights

AICPA Professional Standards in a CPA’s tax practice. IRS Publication 230 and related rules. Personal liability of professionals. Engagement letter protection ideas. Citing of legal cases.

Prerequisites

None.

Designed For

Practitioners involved in federal tax return preparation and/or planning.

Objectives

Review the controlling 2026 professional tax practice ethical standards of the AICPA and IRS. Explore potentially problematic tax situations where a CPA has relatively high personal ethics and/or legal liability exposure. Review of a carefully worded client protective tax return preparation engagement letter to help reduce problematic tax situations.

Preparation

None.