IRS Collection Due Process Procedures (Video) (Course Id 2678)

• Who is this course for?
  This course is designed for CPAs, accountants, and IRS Enrolled Agents who need Continuing Professional Education (CPE) credits and want to understand IRS Collection Due Process (CDP) procedures.

• What is this course about or what problem does this course solve?
  The course covers the legal procedures and taxpayer rights involved in IRS collection actions such as federal tax liens and levies, helping professionals understand and navigate CDP hearings.

• How can the knowledge from this course be used?
  Learners can apply the knowledge to support clients during IRS collection actions, ensuring that due process rights are upheld and helping to explore alternatives when deadlines or procedural challenges arise.

• Why is this course important to a CPA, Accountant, or IRS Enrolled Agent?
  Understanding CDP procedures is critical for professionals who advise clients facing IRS collection actions, as it ensures compliance with tax law and protects taxpayer rights during disputes.

• When is this course relevant or timely?
  This course is particularly relevant any time a taxpayer is subject to IRS enforcement actions, such as liens or levies, or when representing clients during CDP hearings.

• How is a course like this consumed or used?
  The course is delivered as a video-based QAS self-study with no prerequisites or advance preparation required, and includes review and final exam questions to assess comprehension and earn CPE credits.

Due process is, according to Black’s Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed.

Due process involves a series of written or telephone notifications, and it’s all laid out in the tax code and the IRS letters the taxpayer receives in the mail that should definitely not be ignored.
Before the IRS wrecking ball goes into motion, the taxpayer has certain procedural rights. In this presentation, I will discuss them in detail.

Video - NASBA QAS - NASBA Registry - IRS Enrolled Agents - 2678

Course Learning Objectives

1. What are the implications of the Tax Court's decision to not look behind the notice of determination in CDP cases regarding the judicial review process?
2. How does the requirement for a face-to-face hearing impact the taxpayer's experience during the CDP process?
3. In what ways does the suspension of collection actions during a CDP hearing influence taxpayer compliance and behavior?
4. What alternatives do taxpayers have if they miss the 30-day deadline to request a CDP hearing, and how do these alternatives affect their rights?
5. How does the concept of retained jurisdiction by the Appeals Office affect the statute of limitations on tax collection actions?
6. Discuss the potential consequences for taxpayers who raise frivolous arguments during the CDP process. How do penalties serve as a deterrent?
7. How does the judicial review process differ between CDP hearings and traditional tax deficiency cases?
8. What considerations should taxpayers keep in mind when challenging the IRS's proposed collection actions during a CDP hearing?
9. How does the requirement for the Appeals Officer to verify the validity of tax assessments impact the fairness of the CDP process?
10. In what ways can the outcomes of CDP hearings influence taxpayers’ future interactions with the IRS?
11. What role does the notice of determination play in the taxpayer's ability to seek judicial review, and what are the implications of that role?
12. How might the differences in standard of review between tax liabilities and collection activities affect the outcomes of appeals in CDP cases?

Chapter 1 - IRS Collection Due Process Procedures

Chapter 1 Review Questions