With budget cuts and staffing shortages, the IRS has been increasing its use of automation to conduct audits and create substitutes for returns, or “SFRs”. When these computer generated notices come out most taxpayers fail to even open and read them. The result is that nearly 90% of Taxpayers fail to request their appeal of the audit or file a timely tax court petition, resulting in bad audit results becoming final. During this program Tax Attorney Eric Green will explain what practitioners can do to reopen those closed assessments and save taxpayers from the government’s (and their own) foolishness. Eric will cover audit reconsideration, doubt-as-to-liability offers, challenging the tax at a Collection Due Process hearing and qualified amended returns.
Green & Sklarz LLC
Partner
[email protected]
(203) 285-8545
Eric is a partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service, and state Departments of Revenue Services. His practice also handles probate matters and estate planning for individuals and business owners and tax planning for closely-held businesses. He is a frequent lecturer on tax topics for CCH, the NAEA, the NATP, the ABA Tax Section, and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He is the author of The Accountant’s Guide to IRS Collection (available www.tgpublish.com), and he is a columnist for CCH’s Journal of Practice & Procedure. He is also the founder of The New England IRS Representation Conference. Mr. Green is a contributing author for Advocating for Low-Income Taxpayers: A Clinical Studies Casebook, 3rd Edition, and has also been quoted in The Wall Street Journal, USA Today, Consumer Reports, The Wall Street Journal’s Market Watch, TheStreet.com, and CreditCard.com. Before practicing law Attorney Green served as a senior tax consultant for KPMG and Deloitte & Touche. Attorney Green was the 2010 Nolan Fellow of the American Bar Association and has served as Chair of the American Bar Association’s Closely Held Businesses Tax Committee. Attorney Green is the current Chair of the Executive Committee of the Connecticut Bar Association’s Tax Section. Eric is a Fellow of the American College of Tax Counsel (“ACTC”) and a Connecticut, Massachusetts, New York, and American Bar Association member. He is admitted to practice in Massachusetts, New York, and Connecticut Superior Courts, as well as the United States Tax Court, the Federal Court of Claims, and the Federal District Court for Connecticut. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honor graduate from New England School of Law. He earned a Masters of Laws in Taxation (LL.M.) from Boston University School of Law.