Tax Webinar Series

The Four Acts of an IRS Controversy: Act II - Uncommon Strategies for Dealing with the IRS Appeals Office

With the filing of the first tax returns incorporating the changes from the TCJA, coupled with the IRS's LB&I campaigns, businesses can expect increased IRS scrutiny. To help manage this scrutiny, the lawyers of Jones Day's Tax Practice are pleased to invite you to the second webinar in our four-part series, "The Four Acts of an IRS Controversy."

Presented on Thursday, June 13, Act II will focus on strategies for dealing with IRS Appeals under the updated Appeals Judicial Approach and Culture (AJAC) project. In recent years, IRS Appeals has updated its policies through its AJAC project to reinforce its role as a quasi-judicial forum. This presentation will address those policies, along with strategies for large businesses to consider, including:

  1. New strategies for handling potential unagreed IRS exams going to Appeals under AJAC;
  2. How to structure a Protest under the AJAC project;
  3. How to resolve a case with IRS Appeals that isdocketed in U.S. Tax Court;
  4. How AJAC policies impact LB&I's Acknowledgment of Facts (AOF) IDR; and
  5. Strategies for dealing with the new policy of having LB&I Exam and/or IRS Counsel attend an Appeals conference

Jones Day partners Chuck Hodges and Ray Wiacek and associate Aditya Shrivastava will present.

This webinar is the second in a four-part series.

Act I: The Roadmap for Handling a Challenging IRS Examination was presented on March 28, 2019, and is available to view here.

The topics and tentative schedule for the remaining webinars can be found below:

Act III: Alternative Dispute Resolution Techniques in Dealing With the IRS: Why Post-Appeals Mediation Works (Aug. 22, 2019)

Act IV: Litigating a Federal Tax Case: Removing the IRS's Home Field Advantage (Oct.–Nov. 2019)


Registration for this event is required. Register at the Jones Day event site.

This program has been approved for 1.00 hour of general CLE credit by the State Bar of California and 1.00 hour of areas of professional practice CLE credit (including transitional credit) by the New York State CLE Board. This program has been approved for 1.00 hour of CPE credit by NASBA. Jones Day is a State Bar of California MCLE approved provider, an accredited provider in New York, and a registered sponsor with NASBA. Pennsylvania CLE credit is not available for this program. Application for CLE credit in other states will be made as needed.

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