Welcome to Tax Controversy

Tax controversy cases can move quickly, and the right strategy often depends on understanding where the matter stands in the lifecycle of assessment, notice, appeal, and collection. This session provides a practical roadmap for navigating IRS and Maryland tax controversies, with a focus on the procedural tools and resolution options practitioners use most often.

Attendees will learn how to spot critical deadlines, preserve appeal rights, and assess available remedies in audit, collection, and post-assessment situations. The presentation also covers core resolution strategies such as offers in compromise, installment agreements, currently not collectible status, bankruptcy, penalty abatement, innocent spouse relief, and lien-related remedies. Designed for practitioners handling real-world disputes, this course emphasizes strategy, sequencing, and informed client counseling over theory alone.

Learning Objectives:

• Identify the major stages of a tax controversy case, from assessment and notices through appeals and collection.
• Differentiate among IRS and Maryland controversy procedures, including audits, Collection Due Process, and Tax Court rights.
• Recognize the most common collection and resolution tools, including offers in compromise, installment agreements, currently not collectible status, bankruptcy, penalty abatement, and innocent spouse relief.
• Evaluate when each resolution path is most appropriate based on the taxpayer’s facts, financial condition, and procedural posture.
• Outline the key deadlines, filings, and strategic decisions that can affect a taxpayer’s ability to contest or resolve a liability.
• Apply practical judgment to protect client rights, preserve appeal options, and communicate realistic outcomes in tax controversy matters.