Challenging Assessed Taxes: Audit reconsiderations, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing (Presented by Tax Rep)

Eric L. Green
Eric L. Green | Green & Sklarz, LLC.

Eric is a managing partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services.

On-Demand: September 18, 2025

1 hour CLE

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Program Summary

With the challenges of staffing and the pandemic, the IRS has increased its use of automation, including the automated under reporter and automated substitute for returns. Many of these proposed assessments either go unchallenged by taxpayers or, when documents are submitted, they are ignored by the IRS, leading to bad assessments and enforcement against taxpayers. This program will explain the opportunities for practitioners to reopen assessed tax liabilities, including audit reconsideration, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing. The program will explain each option and when practitioners should consider utilizing each of them.

Key topics to be discussed:

  • Understand how to request audit reconsideration
  • Identify when it is possible to use an amended return to reopen a bad assessment
  • Explain how Doubt-as-to-Liability Offers work
  • Understand how to utilize a CDP hearing to force a reconsideration of a tax liability
  • Describe how to use refund requests to reopen a bad assessment

This course is co-sponsored with myLawCLE.

Closed-captioning available

Speakers

Eric L. Green | Green & Sklarz, LLC.

Eric is a managing partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services. He is a frequent lecturer on tax topics for many national organizations, including Insightful Accountant, CCH, the NAEA, the NATP, the ABA Tax Section and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He was the author and lecturer of the University of Connecticut School of Business IRS Representation Certificate Program, and has served as a columnist for CCH’s Journal of Practice & Procedure. He is the founder of Tax Rep LLC which coaches accountants and attorneys on building their own IRS Representation practices, and is the host of the weekly Tax Rep Network Podcast.

Mr. Green is the author of The Accountant’s Guide to IRS Collection, The Accountant’s Guide to Resolving Tax Debts, The Accountant’s Guide to Resolving Payroll Tax Debts and The Insider’s Guide to Offers-in-Compromise.

Agenda

I. Understand how to request audit reconsideration | 3:00pm – 3:05pm

II. Identify when it is possible to use an amended return to reopen a bad assessment | 3:05pm – 3:15pm

III. Explain how Doubt-as-to-Liability Offers work | 3:15pm – 3:30pm

IV. Understand how to utilize a CDP hearing to force a reconsideration of a tax liability | 3:30pm – 3:45pm

V. Describe how to use refund requests to reopen a bad assessment | 3:45pm – 4:00pm

Preview
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