The IRS recently estimated that the tax gap, or the amount of the correct tax liability that is not paid voluntarily and on time, exceeds $458 billion. These liabilities are, not surprisingly, often the subject of enforced collection action by the IRS in the form of levies, lien filings, wage garnishment, and Social Security levies. Because the power to tax involves the power to destroy, Congress granted to taxpayers numerous collection due process rights by which they can challenge the IRS's enforced collection action in favor of one or more collection alternatives.
This webinar, offered by a leading tax controversy attorney, will introduce attendees to:
(1) the Service's various collection mechanisms, including levies, lien filings, wage garnishment, and Social Security levies;
(2) taxpayers' rights to challenge these collection actions;
(3) taxpayers’ rights to request a review of the IRS collection action through Appeals hearings;
(4) various collection alternatives, including offers in compromise on the ground of doubt as to liability and doubt as to collectibility, installment agreements, and currently not collectible status;
(5) strategies to reduce their outstanding liabilities;
(6) strategies to secure these collection alternatives from the IRS in lieu of the enforced collection action; and
(7) the United States Tax Court's jurisdiction to review the IRS Office of Appeals' determinations with respect to these collection due process rights.
This webinar is a must-attend for all practitioners.
Jairo G. Cano is an associate with Agostino & Associates, P.C. He regularly represents clients in complex Federal and State tax controversy matters before the Internal Revenue Service, the New Jersey Division of Taxation and New York Department of Taxation and Finance. Jairo routinely appears on behalf of clients in audits, Appeals hearings, collection proceedings and litigation before the United States Tax Court, New Jersey Tax Court and United States District Courts. Prior to joining Agostino & Associates, Jairo worked for the New Jersey Office of the Attorney General in the Treasury Section where he handled gross income tax, corporation business tax, sales & use tax and various other tax cases. Jairo currently serves as Vice-Chair of the ABA Tax Section’s Diversity Committee. In 2015, Jairo was selected as a Nolan Fellow by the American Bar Association’s Tax Section. Each year, this award is given to a select group of outstanding young tax lawyers from across the country who make significant contributions to the organization and who demonstrate leadership qualities. Jairo graduated from Seton Hall University School of Law and obtained an LL.M. degree in Taxation from the University of Florida Levin College of Law.