Menu
 Log Out
Cart 0 items
Search

Defensive Tax Return Disclosures

 
 Friday, Dec. 14, 2018 from 9:00 am to 11:00 am
 Online
 
2.0
19 / 2-31599
Registration Status: CLOSED -- Please contact the VSCPA at [email protected] or (800) 733-8272 for availability.
VSCPA Members
$79.00 Regular Registration
Nonmembers
$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
Prerequisite:

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.

Syllabus

Lesson 1.

Introduction

Lesson 2.

Forms 8725 and 8725R and Intentional Disregard of Rules and Regulation Penalties

Lesson 3.

Affirmative Equitable Defenses

Lesson 4.

Preempting IRS Deficiency Notice Presumptive Correctness

Lesson 5.

Conclusion

Related Events

Objectives

*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  

*Recognize properly prepared affidavits and incorporated exhibits amount to defensive tax return disclosures that correctly reduce IRS controversies to questions of law

Speakers

Advanced Preparation

None

Vendor

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.