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Defensive Tax Return Disclosures

 Tue, 11/20/2018 from 10:00 am to 12:00 pm
19 / 2-31473
Registration Status: CLOSED -- Please contact the VSCPA at [email protected] or (800) 733-8272 for availability.
Member Price
$79.00 Regular Registration
Your Price
$109.00 Regular Registration
Designed For:

*Recognize important differences in correctly filing Forms 8725 and 8725R*Recognize equitable tax doctrine application can correctly set aside black letter law targeted benefits *Recognize why it is important to correctly rebut the IRS presumption of correctness when filing client tax returns


This webcast is an intermediate continuing education webcast. It is assumed the webcast participant has achieved basic understanding of the following: Equitable tax doctrines, Penalties associated with intentional disregard of rules and regulations, & Issues involving IRS deficiency notice presumptive correctness

Defensive tax return disclosures are made on Forms 8275 or 8275R, depending on whether the declared position is consistent or inconsistent with extant treasury regulations. However, the reason for filing defensive tax return disclosures goes beyond avoiding penalties associated with intentional disregard for rules and regulations. Preempting IRS deficiency notice presumptive correctness is a dominating consideration. This webcast explains.This webcast involves Section 179 depreciation expense at the partnership level in a startup operation. Although not incorporated into this webcast, Dr. Jenkins wants to share his paper, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships or S Corporations." The paper is currently in peer review at a university tax journal. Also, the ACPEN/BPN webcast based on this paper will be first aired during the week of September 25-29, 2017. Please be sure to look for that announcement and register for the webcast.SyllabusLesson 1.IntroductionLesson 2.Forms 8725 and 8725R and Intentional Disregard of Rules and Regulation PenaltiesLesson 3.Affirmative Equitable DefensesLesson 4. Preempting IRS Deficiency Notice Presumptive CorrectnessLesson 5. Conclusion

Delivery Method: Individual webcast
CPE Credit: Taxes
Program Level: Intermediate

The Virginia Society of CPAs (VSCPA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBARegistry.org.

For more information regarding refund, complaint, program cancellation or other policies, visit our Registration Policies page or call (800) 733-8272.