Important CAP Appeal Update


May 25, 2022


Daniel J. Pilla

  1:00 PM ET | 12:00 PM CT | 10:00 AM PT | 120 Minutes

* Not able to attend the live session? We can arrange an on-demand session for You. Please call 1-‪814-892-0304


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 instalment agreements that are arbitrarily rejected/terminated, this course is critical for all tax practitioners.

In this informative webinar 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.

Why Should You Attend?

Full analysis of the statutory authority for Collection Appeal Program (CAP) appeals that involve rejected or terminated instalment agreements (IA). We explain the recent Internal Revenue Manual (IRM) changes that address the authority of the Appeals Office in CAP appeals addressing rejected or terminated instalment agreements.

Attendees will learn:

  • 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. 

Learning Objectives:

  • How to appeal the rejection of Your IRS Installment Agreement
  • Why the IRS rejects installment agreement requests
  • What is the IRS appeals process like?
  • CDPS/CAPS – Collection Appeal Rights

Who Should Attend?

  • CPA’s
  • EAs
  • Other Tax Preparers
  • Tax Attorneys 

Credits and Other Info:

Session Prerequisites and preparation: None

Recommended CPE credit – 2.0

Recommended field of study – Tax

Session learning level: Basic to intermediate

Delivery method: Group Internet Based

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