The American Academy of Tax Practice curriculum is not elementary. The program is redesigned each year for advanced practitioners in IRS procedure and taxpayer representation. The program is divided into ten areas of presentation. In each area brand new material is selected which reflects the latest and most challenging developments which have occurred in the prior year.

Tax Practice Ethics and Professional Standards – this area includes material which constitutes the annual 2 CPE hour ethics requirement for enrolled agents. It is designed to challenge advanced taxpayer representatives with respect to IRS employee misconduct, taxpayer harassment, and ethical dilemmas which face more aggressive practitioners. The unit includes consideration of cases resulting in both IRS employee and practitioner discipline.
2008 Feature: Significant changes to Circular 230 – Definition of Practice, Return Preparation Standards, Who can practice, preparer penalties and more

Internal Revenue Service – This area is designed to keep practitioners fully aware of the changing delegations of authority within the IRS organization and to insure that participants know every technique for overcoming dilatory responses in connection with levy releases, lien withdrawals, collection due process determinations, and all of the resolutions experienced taxpayer representatives regularly need.
2008 Feature: Analysis of IRS guidance and policy changes associated with a new commissioner.

Filing and Reporting – This unit is devoted to the intricacies of filing requirements, delinquent return submission, payment applications. It considers proof of filing, the difference between deposits against tax liabilities and advance payments on deficiencies, payoff statements as opposed to closing agreements, and many other complexities encountered in difficult cases.
2008 Feature: New disclosure rules and prohibitions.

Examination – This unit is one of the pillars of the Academy. Advanced practitioners must know how to protect their client’s rights when they have been selected for examination. Understanding the IRS search for information, understanding the techniques of examination, understanding the issues the IRS is emphasizing in any particular are imperatives for advanced practitioners. The ability to defend inadequate salary disputes, the ability to follow reconstruction opportunities in no record cases, and the ability to understand the special vulnerabilities of taxpayers in unusual situations are all the substance of this area. Containing and controlling aggressive agents and non-responsive supervisors within the bounds of the practice regulations is another objective of this unit.
2008 Feature: The out of control exam on unreported income. Case Study

Collection – This unit is the second pillar of the Academy. Updating is a practitioner’s absolute responsibility with respect to the impact of the IRS federal tax lien and the effect it has as a secured interest in a taxpayer’s property. Lien relief in the form of partial discharges or subordinations as well as lien withdrawals together with the financial hardship regulations associated with levy release are essential for advanced practitioners. An understanding of the available IRS judicial remedies, seizure of tenant by the entirety interests, and the increasing use of the IRS of foreclosure proceedings are essential practitioner concerns. Pursuing solutions under Section 6159 which do not result in full payment and solutions under section 7122 which involve special circumstances are a specific concern of this unit. Representing the most troubled taxpayers in need of criminal privilege by means of attorney Kovel agreements and a full understanding of the elements of the offense of willful failure to file contained in section 7203 are essential elements.
2008 Features: The new IRS IRM collection procedures in depth. Collection Due Process Case Study. Statute expiration determinations.

Appeals – This unit tracks the ever changing role of the settlement function in both examination and collection cases. Growing opportunities in qualified settlement offers, administrative fee recovery, compromise at the appellate level, and the power of mutual concessions are pursued in depth. Opportunities in the equitable resolution of joint liability relief presented by recently decided cases. Effective settlement proposal and the art of settlement negotiations are discussed in detail.
2008 Feature: Appeals function dilemma: increasing work load, decreasing personnel.

Criminal – This unit is emphasized or de-emphasized depending on the activities of the IRS criminal investigation function. Tax shelters, offshore activities, and large dollar non-filing are currently targeted areas which are continued areas of discussion and consideration.
2008 Feature: Practitioner Projects

Employment Tax – This unit is most often devoted to the changing emphasis on the IRC 6672 trust fund recovery penalties asserted in the face of failures to withhold or turn over trust fund monies by corporate personnel including the newest court cases which shed light on the concepts of responsible persons and willful failures. In addition, the unit includes the growing abuses and dangers to taxpayer employers associated with classifying workers and employee leasing.
2008 Feature: Trust fund penalty developments and worker misclassification solutions.

Penalty Administration – Avoiding and recovering penalty assessments continues to be a needed service in the face of increasing reluctance by IRS personnel to grant relief. As the Service continues to automate the decision making process in its abatement and refund procedures, greater skill is needed by practitioners in articulating the elements of reasonable cause. This unit is devoted to maximizing participant’s capabilities in this area.
2008 Feature: Tax understatements, negligence and civil fraud.

Practice Management and Tax Law Research – This unit is designed to maximize the effectiveness of federally authorized tax practitioners in the areas of information within and without the IRS. In the ever changing world of IRS operations, no practitioner can afford to be left behind. This unit covers the latest in available knowledge for setting fees, getting paid, and running a cutting edge practice.
2008 Feature: Importance of standard office practices

Twenty-four hours of non-stop professional education that meets the high standards contemplated by the IRS Office of Professional Responsibility for enhancing the capabilities of federally authorized tax practitioners who represent taxpayers before the IRS.