2018 Taxpayers Defense Conference - The Nation's Top IRS Seminar
for Tax Professionals

Monday & Tuesday - October 22 & 23, 2018

9:00 AM to 5:00 PM CST
Minneapolis, Minnesota
Embassy Suites - Minneapolis Airport

2018 Detailed Agenda


Session 1: IRS’s Future State

Dan Pilla addresses the current enforcement initiatives announced by the IRS, with particular focus on crypto-currency enforcement. Pilla also analyzes the IRS’s new five-year strategic plan that outlines the agency’s long-term goals regarding enforcement and administration.

Session 2: Section 199A of the Tax Cuts and Jobs Act

Dan Pilla analyzes new code §199A, created under the Tax Cuts and Jobs Act. This is the section that creates the 20% deduction for small businesses and self-employed persons. It is a complex calculation and the deduction is dependent upon a number of fact considerations. Pilla provides numerous examples to illustrate the calculations and reviews the new proposed regulations issued by the IRS on this matter.

Session 3: Revocation of Passports

Dan Pilla explains the law allowing the IRS to certify certain taxpayers to the State Department as “seriously delinquent” if they owe more than $50,000. We examine what constitutes being “seriously delinquent,” the required “notice” process, what the exceptions are, and how the available appeal procedures work.

Session 4: The Innocent Spouse Rules

Dan Pilla provides a full analysis of the provisions of code §6015(b) and (c), the innocent spouse and separate spouse election rules, along with IRS Form 8379. Special emphasis is put on the burden of proof a taxpayer must carry to establish entitlement to innocent spouse relief.

Session 5: Innocent Spouse Equitable Relief

Scott MacPherson addresses code §6015(f), the so-called “equitable relief” provision under the innocent spouse rules. Separate rules apply under §6015(f) if a taxpayer does not qualify for relief under either §6015(b) or (c). This is an important provision because there is no statute of limitations on a taxpayer’s right to apply for relief under this provision, contrary to both §6015(b) and (c)


Session 6: Live Role-playing of Innocent Spouse Scenarios

The attendees are broken into eight separate groups and each group is presented with a set of facts regarding a hypothetical innocent spouse case. All the facts are derived from actual cases. The groups must present arguments to defend the taxpayer and assert a potential innocent spouse defense based on the facts and applicable law of the case based on all the teachings of the previous day’s sessions. Each group will feature an experienced tax pro playing the part of an IRS officer.

Session 7: Evaluation and Critique of Role-playing Sessions

Dan Pilla, Scott MacPherson and other TFI staff review, critique and analyze each of the mock negotiation sessions. We analyze the strengths and weaknesses of each presentation, evaluate the performance of each participant, and discuss potential alternative approaches under the circumstances.

Session 8: Ethical Considerations for Entertainment Expenses

The Tax Cuts and Jobs Act changed considerably the rules for deducting business entertainment expenses for years beginning in 2018. The narrow definition of “entertainment” expenses in §274 and its regulations raise serious ethical considerations for tax pros in the preparation of business tax returns. Pros must be aware of the applicable definitions, they must caution their clients regarding what is an “entertainment” expense (and thus non-deductible) and what is an otherwise allowable business expense (and thus fully deductible). Dan Pilla analyzes the various elements of §274, include the infamous §274(d), which carries very strict record-keeping rules for deducting business meals, travel and entertainment expenses. Tax pros must know these rules and must ensure that their clients know these rules order to, a) avoid claiming expenses that are not deductible, and b) taking the benefit of deductions that are otherwise perfectly legal.

Session 9: Moderated Discussion

Group discussion of problems, questions and strategies based upon all earlier presentations. We will present and discuss hypothetical cases involving various aspects of IRS negotiations.

Course Description

IRS's Future State with emphasis on Innocent Spouse Claims

Each year since 1993, Tax Freedom Institute founder and Executive Director, Daniel J. Pilla has presented the nation’s leading seminar for tax professionals, the Taxpayers Defense Conference. Designed specifically for tax pros in the business of helping taxpayers solve IRS audit, appeal and collection problems, Dan reveals the latest on exactly what to expect from the IRS and exactly how you can best help your clients weather the latest storm. To serve your clients in the best possible way, you need to know how to protect and defend your clients. That’s where the Taxpayers Defense Conference comes in.

What to Expect at a Taxpayer Defense Conference

Each year, Dan Pilla personally prepares the presentation topics for the Defense Conference. His topics always include the latest trends in IRS enforcement actions, court decisions, tax legislation and clients’ needs. Here is just a small sampling of some of our prior topics:

  • Dealing with IRS Correspondence
  • Audit-proofing and Penalty-proofing Strategies
  • Canceling Penalties and Interest
  • Handling Correspondence Audits and Face-to-face Meetings with Revenue Agents
  • Audit Appeal Procedures
  • Petitioning the Tax Court in Audit Cases
  • Negotiating with the Appeals Office and IRS Counsel
  • Understanding and Minimizing Liens, Levies and Seizures
  • Negotiating with Revenue Officers
  • Utilizing the Office of the Taxpayer Advocate
  • Negotiating Installment Agreements, Offers in Compromise, Uncollectible Status
  • Negotiating Innocent Spouse Claims
  • Collection Due Process Appeals
  • Tax Court Collection Due Process Cases
  • Understanding the Collection Statute Expiration Date
  • Claims for Refund
  • Professional Responsibility
  • Recovering Professional Fees and Costs.
  • Networking with Some of the Nation’s Most Experienced Attorneys and Accountants
This year's conference will focus on current enforcement initiatives announced by the IRS, including crypto-currency enforcement, areas of the Tax Cuts and Jobs Act, and special emphasis on Innocent Spouse rules.

Topics will include:

  • IRS’s Future State
  • Section 199A of the Tax Cuts and Jobs Act
  • Revocation of Passports
  • The Innocent Spouse Rules
  • Innocent Spouse Equitable Relief
  • Live Role-playing of Innocent Spouse Scenarios
  • Ethical Considerations for Entertainment Expenses

Daniel J. Pilla

Daniel J. Pilla

Daniel J. Pilla is a tax litigation consultant, licensed to practice in US tax Court as well as an Enrolled Agent.
Dan is a 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 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.

The 2 Day Seminar includes

1- Seminar Attendance Certificate

2- Seminar Material

2- Buffet lunch included both days*

Venue Details:

Monday & Tuesday - October 22 & 23, 2018

9:00 AM to 5:00 PM CST
Minneapolis, Minnesota
Embassy Suites - Minneapolis Airport


Continuing Educational Credits available for all Tax Pros 13.25 Total (includes 1.75 Ethics)

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