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      Tax Freedom Institute
Daniel J. Pilla


 Taxpayers Defense Conferences - Solving IRS Problems

The Nation's Top IRS Seminar for Tax Professionals


2019 marked our 25th anniversary of 

Taxpayer Defense Conferences!


2019 Taxpayers Defense Conference

Theme: Employment Tax Compliance

Missed it? 
Audio sets available now


2020 Taxpayers Defense Conference

Monday & Tuesday - October 26-27, 2020

Save the dates -mark your calendar now.

 Luxor Hotel and Casino
Las Vegas, Neveda 

Continuing Educational Credits available for all Tax Pros 

2019 Taxpayer Defense Conference Theme:
Business Tax Liabilities

Small businesses make up the fastest going segment of federal income tax return filers. The number grows by millions every year as more people look for ways to supplement their incomes and gain financial independence. The problem is most people who set out in business have no idea how to meet the dozens of compliance burdens the tax code heaps on business owners. The GAO once counted more than 200 distinct obligations placed on the shoulders of businesses. Can you name all 200? Can you name even 20? Most people can’t. That’s why so many end up in trouble with the IRS. What starts as a dream to gain financial independence often ends as a nightmare when the IRS imposes tens of thousands in unexpected taxes and penalties.

To address this, the 2019 Taxpayers Defense Conference will focus on business tax liabilities. We will address common small business problems with sessions as follows.

The Taxpayer First Act
This session addresses the Taxpayer First Act, enacted July 1, 2019. In particular, we will analyze the legislative changes to the IRS’s Office of Appeals and procedures related to identity theft cases. These procedures are reviewed from the standpoint of both the IRS and the ID theft victim. 

The Trust Fund Recovery Penalty 
This session analyzes new code §6672, which creates personal liability for corporate officers and employees responsible for not paying employment taxes. We analyze the legal basis for liability, the circumstances under which a person may be found liable, defenses to the penalty, how to present defenses, and appeal procedures specific to the penalty. 

Employment Tax Compliance Generally 
This session explains the general requirements employers must meet to be in compliance with employment tax law, including Form 941 compliance, periodic deposit requirements, reasonable compensation rules for employees performing services for a corporation, and rules related to Forms W-2 and W-9. 

The Voluntary Classification Settlement Program 
This session addresses the IRS’s program that allows employers to seek a determination on the status of workers they designated as independent contractors. Employers entering the program can obtain a definitive ruling on the employment tax status of their workers and thus avoid retroactive penalties for misclassifying workers. 

Alter Ego/Nominee Rules 
This session addresses the legal doctrines of alter ego/nominee in the context of employment tax penalties and the Trust Fund Recovery Penalty. Emphasis is placed on the circumstances under which the IRS will pursue collection of an employment tax assessment owed by one corporation against a successor corporation. 

Live Role-playing of Employment Tax Scenarios with Evaluation and Critque of Role- playing sessions
The attendees are broken into eight separate groups and each group is presented with a set of facts regarding a hypothetical case involving the topics presented. All the facts are derived from actual cases. The groups must present arguments to defend the taxpayer and assert a potential defense based on the facts and applicable law of the case based on all the teachings of the previous day’s sessions. Each group features an experienced tax pro playing the part of an IRS officer. Afterwards, Pilla, MacPherson and other TFI staff review, critique and analyze each of the mock negotiation sessions. We analyze the strengths and weaknesses of each presentation, evaluate the performance of each participant, and discuss potential alternative approaches under the circumstances. 

Avoiding “Aiding and Assisting” Preparer Penalties
This session will address both civil and criminal penalties against tax professionals for aiding and assisting a taxpayer in the acts of a) submitting a false claim to the IRS regarding a material matters, and b) evading taxes. Special attention is given to the question of what constitutes “aiding” when it comes to tax evasion. This is particularly relevant to our audience since all attendees are actively involved in representing clients before the IRS who owe substantial unpaid tax debts. We will analyze the various elements of “evasion,” what the IRS must prove to establish an “aiding” case, and how to avoid potentially questionable conduct when it comes to advising clients with tax delinquencies.

Moderated Discussion 
Group discussion of problems, questions and strategies based upon all earlier presentations. We will present and discuss hypothetical cases involving various aspects of IRS negotiations.  This is a favorite of our attendees as attendees are invited to bring in cases they wish to discuss with the group.


MISSED Prior Conferences?

AUDIO recordings available!

Click here for prior Taxpayers Defense Conference information.


Taxpayers Defense Conferences

Each year since 1993, Tax Freedom Institute founder and Executive Director, Daniel J. Pilla has presented the nation’s leading seminar for tax professionals, the Taxpayers Defense Conference. Designed specifically for tax pros in the business of helping taxpayers solve IRS audit, appeal and collection problems, Dan reveals the latest on exactly what to expect from the IRS and exactly how you can best help your clients weather the latest storm. To serve your clients in the best possible way, you need to know how to protect and defend your clients. That’s where the Taxpayers Defense Conference comes in.




Each year, Dan Pilla personally prepares the presentation topics for the Defense Conference. His topics always include the latest trends in IRS enforcement actions, court decisions, tax legislation and clients’ needs. Here is just a small sampling of some of our prior topics:

  • Dealing with IRS Correspondence
  • Audit-proofing and Penalty-proofing Strategies
  • Canceling Penalties and Interest
  • Handling Correspondence Audits and Face-to-face Meetings with Revenue Agents
  • Audit Appeal Procedures
  • Petitioning the Tax Court in Audit Cases
  • Negotiating with the Appeals Office and IRS Counsel
  • Understanding and Minimizing Liens, Levies and Seizures
  • Negotiating with Revenue Officers
  • Utilizing the Office of the Taxpayer Advocate
  • Negotiating Installment Agreements, Offers in Compromise, Uncollectible Status
  • Negotiating Innocent Spouse Claims
  • Collection Due Process Appeals
  • Tax Court Collection Due Process Cases
  • Understanding the Collection Statute Expiration Date
  • Claims for Refund
  • Professional Responsibility
  • Recovering Professional Fees and Costs.
  • Networking with Some of the Nation’s Most Experienced Attorneys and Accountants

Taxpayers Defense Conference Special Features

In addition to the cutting-edge topics that place and keep you ahead of the curve when it comes to defending your clients before the IRS, the Taxpayers Defense Conference also features:

  • Live interactive brain storming sessions with some of the nation’s most experienced Attorneys, CPAs and Enrolled Agents. Bring your problem cases to the Defense Conference and return to work with renewed ideas and energy.
  • Up to 50 pages of written outline material that includes tax code sections, regulation, Internal Revenue Manual references, court decisions and other legal authority. This material is unique in its organization and invaluable as future reference material. You will not want to throw it away. In addition, you get our Master Index of all prior Defense Conference topics. All of our prior seminars are available for purchase on CDs.
  • Continuing education credits for every conference, often including ethics credits, on topics that are important to your practice and your clients. You’ll waste no time at the Taxpayers Defense Conference.  
  • Networking with Tax Freedom Institute members from around the nation, and personal interaction with Dan Pilla at the conference.
Our two-day conference is widely regarded as simply the best tax seminar in the nation for those practicing in the areas of taxpayers’ rights issues and IRS problems resolution. If you are looking for information on how to prepare tax returns, this conference is not for you. But you want to get and stay on the cutting edge of taxpayers’ rights issues and need to know more about how to represent and protect your clients in IRS enforcement situations, there just is no better place in the country to do so than at the Taxpayers Defense Conference.


You Benefit from Dan’s Experience

Admitted to practice for the United States Tax Court, a Tax Litigation Consultant and author of 13 books, dozens of research reports, and hundreds of articles on IRS defense strategies, Daniel J. Pilla has been on the cutting edge of taxpayers’ rights defense for over three decades. He was a consultant to the National Commission on Restructuring the IRS. His book, The IRS Problem Solver, was ranked by the Wall Street Journal as the number one tax book in America. Simply put, nobody has more experience in handling the IRS – and never has that experience been more important than in our current tax enforcement environment. The Associated Press said, “Pilla probably knows more about the IRS than the commissioner.”

Dan’s uses his unmatched skills in research, writing and teaching to present two days worth of live sessions on the latest laws, procedures and strategies that affect how you deal with the IRS in problems resolution cases. For years, the Taxpayers Defense Conference has been sought after by attorneys, CPAs, Enrolled Agents, tax preparers and others in the tax and financial world, precisely because there is simply no place else in America to get the kind of information that’s presented by Dan in the Taxpayers Defense Conference. 

Read What Others Say About These Conferences

The Taxpayers Defense Conference is so unique and powerful in its ability to help you help your clients, it’s no wonder that more than 97% of the tax pros who’ve attended our seminar in the past say they would come back again.    In fact, many tax pros have attended this conference for more than 15 years in a row. How many seminars can you say that about?


The Taxpayer Defense Conference is what I wait for all year.  If you’ve been to one, you know what I’m talking about—THE BEST TAXPAYER DEFENSE CONFERENCE IN THE WORLD!  I know that most of you have attended many hours of continuing professional education in your career.  And I would bet the word that best describes the majority of CPE you’ve attended is . . . BORING.  The TFI Defense Conference is definitely NOT boring.  It’s not a bunch of stuffy egghead law professors and sleepy accountants droning on about esoteric crap that might affect less than 1% of your clients.  The TFI Conference is a hands on participation event that teaches you the best and most effective methods for solving IRS issues we deal with every day.  This year’s conference theme, “Installment Agreement Negotiations”, will be no exception.  Negotiating installment agreements is a very important part of most of our businesses.  The hands-on role-playing we will do on Tuesday of the Conference will definitely help us to effectively deal with the toughest Revenue Officers and Appeals Officers.  If you’re new to TFI, you should definitely attend.  You will meet folks who’ve been fighting the IRS for decades and winning, and you will leave the conference with a LOT of practical tools that will boost your business and please your clients.

    Paul R Tom- Attorney

After reading this year's (2015) agenda which focuses on Offers in Compromise, I think this could be the best Defense Conference ever.  Offers are a big part of my practice and I have had tremendous success with them in the last few years.  They are an incredibly valuable tool.

Dan is bringing back the role-playing sessions he introduced last year when he concentrated on CDPs.  He put the attendees in groups and gave them different CDP problem cases.  They each argued their case in front of a Settlement Officer.  Dan then went over each scenario and everyone in the room discussed the case and how to win it.  This year, he is putting together some of the biggest objections brought up by the IRS in OIC cases.
I can guarantee you the following:
        1.  No matter how much you think you know about Offers, Dan will dissect the IRM and present tools, tips, and tricks you do not know.
        2.  You will have more Offers accepted this year than last.
        3.  More accepted Offers means higher fees.
        4.  When the role-playing session is done, you will know how to solve the toughest OIC cases.
        5.  The brainstorming sessions are gold and not just limited to Offers.  Bring your toughest case and it will be solved.
        6.  You will network with highly skilled tax professionals who do not think you are strange because you find that dealing with
                and fighting the IRS is interesting and fun.
        7.  You will leave the Conference pumped up and at the top of your game.
        8.  You will love the little desserts at the free buffet lunches.
If you have never been to the Defense Conference, this is the year.   
         Steve Klitzner - Attorney



“If you can attend just one seminar this year, make it the Taxpayers Defense Conference. It’s the best tax controversy conference in the U.S. There’s nobody better than Dan Pilla.”           Tommy S. – Attorney

“If you’ve not attended, you’re missing the best opportunity you have to network with the best in the country. As far as I’m concerned, it’s a must.   Leo S. – CPA

“This event is a ‘must attend’ for even the most experienced tax practitioners. Dan has the inside track on the latest IRS policy and procedural changes. He’s a walking encyclopedia on IRS procedures. His written material is well-organized and provides an excellent resource for future reference.”      Don M. – Attorney

“I’ve attended your conferences for the last ten years. I’m always impressed with the quality of your presentation. I cannot get this information from any other source. I appreciate your tireless preparation each year."     Judy J. – Enrolled Agent

“The Taxpayers Defense Conference exceeded my expectations as far as useful and informative information and outlines. The information will substantially assist me in my dealings with the IRS on behalf of my clients.”     Jim C. – Attorney

“This conference is cutting-edge taxpayer defense advice from the best in the country. There’s no better tax seminar on the planet. I’ve only missed one in the last 17 years. Don’t miss the opportunity to brainstorm with the best tax pros in the business. Paul T. – Attorney


Don't Miss 2020!  

Prior Conferences 

 Click here for Taxpayers Defense Conferences Details and Audio Sets

 You can also call to order prior years audio outline sets  (2006 on) for just $149 per year plus $10 shipping. 
Sets include  USB MP3s audio of sessions and outlines, no CE.
Call 1 800 346-6829 to order!


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