2021 Curriculum.     24 Hours of Hard Hitting CPE

The Internal Revenue Code contains about 12 sections (not counting penalty sections) that authorize the IRS to enforce taxpayer compliance with tax law in general. On the other hand, the Internal Revenue Code contains about 30 sections that permit taxpayers to mitigate the effects of the IRS enforcement measures. Federally authorized tax practitioners must know and understand the sections of the code depended upon by the IRS to enforce taxpayer compliance but more importantly, federally authorized tax practitioners must know and be able to invoke the mitigating sections of the Internal Revenue Code to serve their clients effectively. This is the master's level of taxpayer representation competence.

AATP 2021 will delve into the reasons The Code is the "best friend" of taxpayers and the practitioners who represent them before the IRS. We will consider the oppressive sections of the Code depended upon by the IRS to enforce the law as well as the sections of the Code that mitigate the effects of enforcement on taxpayers. We will dwell on the sections enhanced by Treasury Regulations and look at the leading court cases concerning the mitigating Code sections. Our purpose will be mastering use of the law to assist our clients who must deal with the IRS when they are examined, when they are unable to pay what they owe in full, and when they wish to appeal determinations made by IRS personnel. Our clients deserve no less.