Understand Important CAP Appeal Update


May 05,2022

PRESENTER(s): Daniel J. Pilla

1:00 PM ET | 12:00 PM CT | 10:00 AM PT | 120 Minutes
  • Webinar Instruction will be emailed on your registered email address 3 days prior to webinar
  •  | 
  • Web Download / e-Transcript will be shared in 7 working days from the date of webinar

This program has been approved IRS CPE Credit 2(Taxes)

The IRS regularly rejects or terminates IAs. If this happens when a taxpayer has no Collection Due Process appeal rights, options for challenging the decision are limited. This course gives you the tools needed to launch a successful and effective CAP appeal. Given the number of installment agreements that are arbitrarily rejected/terminated, this course is critical for all tax practitioners. 

Full analysis of the statutory authority for Collection Appeal Program (CAP) appeals that involve rejected or terminated installment agreements (IA). Mr. Daniel explain the recent Internal Revenue Manual (IRM) changes that address the authority of the Appeals Office in CAP appeals addressing rejected or terminated installment agreements. Attendees will understand the full statutory background for IA appeals, and how to deal with the Independent Office of Appeals in carrying out a CAP appeal that involves a rejected or terminated IA. This includes understanding the burden of proof and how to carry it out. 

Learning Objectives:

  • The history and purpose of the CAP program
  • The statutory background on IA appeals
  • What the specific rights are of taxpayers in IA appeals
  • How the Appeals office historically handled IA appeals and why they deprived taxpayers of their statutory right to appeal
  • The difference between a CAP appeal and a Collection Due Process Appeal
  • How the IRM changed the manner in which Appeals is required to address IA appeals
  • Understanding the burden of proof in IA appeals
  • Examination of recently successful IA appeals using the new IRM provisions.

Participants will understand:
Upon completion of this course, you will be able to:

  • How to Execute a Successful CAP appeal in Installment Agreement Cases
  • Understanding Installment Agreement Appeals
  • The Keys to Success in Executing Installment Agreement Appeals
Credits and Other information:
  • Recommended CPE credit – 2.0
  • Recommended field of study – Taxes
  • Session Prerequisites and preparation: None
  • Session learning level: Basic
  • Location: Virtual/Online
  • Delivery method: Group Internet Based
  • IRS Course ID: PJGWS
  • Attendance Requirement:  Yes
  • Session Duration: 2 Hours
    • Case Studies and Live Q&A session with speaker
    • PowerPoint presentation for reference

Who Will Benefit:

  • Certified Public Accountants (CPAs)
  • Enrolled Agents (EAs)
  • Tax Professionals
  • Tax Attorneys
  • Tax Compliance Managers
  • Other Tax Preparers
  • Accountants

Speaker Profile:

Daniel J. Pilla is a tax litigation consultant, premier proponent and advocate of taxpayer rights. For over three decades, Dan has been tremendously successful in his negotiations with the IRS. Regarded as one of the country’s premiere experts in IRS procedures, Dan provides people across the country with sound solutions to their tax-related problems. He has helped countless thousands of citizens solve personal and business tax problems they thought might never be solved. Furthermore, Dan’s proven techniques can effectively prevent IRS problems before they begin.

Dan is the author of over fourteen books, dozens of research reports and hundreds of articles. Dan’s work is regularly featured on radio and television as well as in major newspapers, leading magazines and trade publications nation-wide. His books have been recommended by prominent magazines and financial publications such as the Wall Street Journal, Money, Family Circle, Investor’s Business Daily. The Wall Street Journal ranked Dan's book, “The IRS Problem Solver”, as the number one tax book in America. Dan has written or contributed to major articles for Reader’s Digest, National Review, Reason, USA Today Magazine and others.

Dan was a consultant to the National Commission on Restructuring the IRS. He works with numerous public policy research institutes and presented testimony to Congress on several occasions. His testimony to the Senate Finance Committee blew the lid off IRS abuse and led to many new taxpayers’ rights and protections. He is admitted to practice before the United States Tax Court where he represents taxpayer across the nation

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