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Resolving Issues with the IRS Exam and Collections Divisions

June 25, 2020 1:00 PM EST | 02:30 PM EST

Training Duration = 90 min              Sponsored by Lorman

Click Here to register $219.00

Click Here to register and receive downloadable recording $288.00

In representing clients before the IRS’s exam and collections divisions, the practitioner needs to be aware of a myriad of rules, and internal IRS procedures. This topic will provide negotiation tips for installment agreements, offers in compromise and what to do when faced with a residence seizure. The material will also address selling real estate after a lien has been filed and how to best represent high income non-filers who have been recently targeted by an IRS initiative. The information will also provide tips on eggshell audits; responding to information document requests and summonses; as well as audit reconsideration and tax court. Finally, the content will address IRS initiatives during the pandemic and how the postponement of certain deadlines will impact our practice years from now.

Learning Objectives

  • You will be able to describe strategies for handling a collection case.
  • You will be able to discuss the best way to handle an audit.
  • You will be able to explain how recent legislation and IRS initiatives can help your client in a collection or audit case.
  • You will be able to recognize when a civil audit could be going criminal.


Navigating the IRS Collection Process
  • Installment Agreements – Including Negotiating High Dollar Balance Due Agreements
  • Offers in Compromise Including Advanced Negotiating Tips
  • Residence Seizures
  • Selling Real Estate After a Lien Has Been Filed Against the Taxpayer
  • Collection Activities for High Income Non-Filers and Tips for Representing These Taxpayers
  • Collection Due Process Dos and Don'ts
Grappling With an IRS Field Audit of Your Client
  • Eggshell Audit
  • Responding to Information Document Requests and Summonses
  • Privilege Issues
  • Audit Reconsideration Pitfalls
  • Tax Court
Special Considerations During the Pandemic
  • Which IRS Activities Have Been Suspended and Which Will Continue During the Pandemic
  • Communicating With the IRS During the Pandemic
  • How Pandemic Deadline Postponements Will Impact Our Practice Several Years From Now

Instructor Profile:

Dennis Brager

Brager Tax Law Group

  • Founder of the Brager Tax Law Group – a worldwide practice limited to representing clients having criminal and civil disputes with the IRS, the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department
  • Former Senior Trial Attorney for the Internal Revenue Service’s Office of Chief Counsel
  • California State Bar Certified Tax Specialist
  • Frequent lecturer at the UCLA Tax Controversy Institute and University of Southern California
  • Appeared on ABC’s Television show Good Morning America, Fox Business News, KFWB Money 101, and KABC’s The Larry Elder Show
  • Author of articles that have appeared in California Lawyer, Daily Journal, Taxation for Lawyers, Los Angeles Lawyer, The Consumer Advocate, Family Law News, California Tax Lawyer, Journal of Tax Practice and Procedure, Journal of Tax Investments, and Marijuana Venture
  • Quoted as a tax expert by Business Week, The Daily Journal, The Daily Beast, USA Today, Tax Analyst, The Chicago Tribune, CNN Money, Bloomberg BNA, Accounting Today, Tax Notes Today, and The National Law Journal
  • Former chair of both the Tax Compliance, Procedure and Litigation Committee of the Los Angeles County Bar Association and the California State Bar, Tax Procedure and Litigation Committee
  • Can be contacted at 310-208-6200 or

Fran Obeid


  • Founder of MFO LAW, P.C.
  • Represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the tax division of the Department of Justice, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General as well as other government agencies
  • Has represented numerous clients residing throughout the world with undisclosed offshore accounts advising on disclosure and compliance alternatives and guiding them through the process
  • Defends clients in federal and New York State audits, including residency and sales tax audits and advises on how to prevent such audits
  • Represents nonfilers; alleged responsible persons and has successfully obtained significant abatements of penalties; has also represented individual witnesses and accounting firms before the U.S. Attorney’s Office, the Criminal Investigation unit of the IRS as well as before the New York State Attorney General
  • Regularly interacts with revenue officers, IRS Appeals officers, criminal investigators and agents, Assistant United States Attorneys and Assistant Attorney Generals, taking the right approach to best meet the client’s needs, whether it be defending a civil examination, criminal investigation or indictment, or subpoena demand
  • Authored numerous articles and has been a panelist concerning topics such as IRS and state tax collection enforcement techniques, including passport revocation and driver license suspension, as well as the government’s enforcement of offshore accounts and its voluntary compliance programs
  • Former chair of the Personal Income Taxation Committee at the New York City Bar
  • Fellow of the American College of Tax Counsel and has been named a Super Lawyer in the tax field for 2019
  • Can be contacted at 212-628-3990,, or