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This program was recorded on September 3, 2020
John Butler, US Tax Court barred Attorney, conducts a seminar on the basics of defending IRS audits and minimizing damage to the client. Additionally, he will discuss tactics, procedure, and more. Finally, he will conduct a brief discussion on how to correct already-closed audits.
John Clayton Butler
John grew up in Amherst, New Hampshire. John attended Dickinson College in Pennsylvania graduating with a major in Computer Science and Mathematics. A full academic scholarship to Tulane Law School brought him to New Orleans in 2004, where he has stayed ever since. After becoming certified and barred in the United States Tax Court in 2008 John has operated his own firm in complex tax planning and defense for the past eleven years. In that time, John has personally handled thousands of advisory cases, tax workouts, criminal defenses and requests for specific tax advice on behalf of clients ranging from individuals to local businesses to Fortune 500 financial institutions. Often, John is brought in as tax counsel in cases that are not tax cases but have tax aspects. The most common are Chapter 11 bankruptcies where taxes are owed to the IRS by the debtor, divorce where the married couple jointly owe the IRS and criminal defense where tax charges make up part of the indictment.
1 General Credit
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- Setting the Table: The documents you will need to start an audit.
- The Pre-Meeting Audit and Establishing Goals
- To Disclose or Not to Disclose: That is the Question
- Vow of Silence?: should your client talk? Short Answer: No. Long Answer: Also no.
- The Three Types of Audits – Desk, Drive-By, Full
- The Four Horsemen of the Audit Apocalypse: Referrals, Expansions, Lookbacks, and 6662(a)(1)(A). How to handle? When to engage Area Counsel?
- Devil is in the details: What do you do when you disagree with the auditor. The Internal Revenue Manual (IRM). Why this is not like litigation.
- Happily Ever After: Know when to say when.
- Taking it to the Limit… One More Time: When and How to Petition the USTC.
- Old and Cold–How late is too late to contest the validity of a tax debt?