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Courses/Law/Tax Law

Anatomy of a Civil Tax Controversy Part 1

Navigate the complex initial stages of a civil tax controversy, from audit through IRS appeals, to strategically protect your clients and mitigate potential tax liabilities.

Created byMichael J. DeBlis III, Esq.
BeginnerUpdated Sep 16, 2025
Anatomy of a Civil Tax Controversy Part 1

What You'll Learn

check_circleDiscern the stages of a civil tax controversy.
check_circleIdentify the significance of a 30-day letter.
check_circleUnderstand the role of the IRS Appeals Division.
check_circleDistinguish options presented by a 90-day letter.
check_circleGrasp tax court petition procedures.
check_circleRecognize the impact of an IRS assessment.

About This Course

Delve into the intricate world of "Anatomy of a Civil Tax Controversy Part 1," a foundational course guiding you through the initial stages of disputes with the IRS. Taught by an expert with extensive experience, this course illuminates the often-complex journey of tax controversies, from audit to potential litigation.

Understand the critical phases and strategic decisions involved:

  • Identify the various types of tax examinations and the IRS's audit process.
  • Navigate the "Thirty Day Letter" and its implications, including options for requesting an IRS Appeals Division conference.
  • Comprehend the significance of the "Ninety Day Letter" (Notice of Deficiency) and the crucial decision between paying the asserted deficiency or petitioning the Tax Court.
  • Explore the process of petitioning the Tax Court, discovering who represents the IRS and the strategic advantages of negotiation with IRS Chief Counsel attorneys.
  • Grasp the critical concept of an IRS assessment and its impact on a taxpayer's liability and collection actions, including liens and levies.
  • Uncover the complexities of "Eggshell Audits," where civil examinations unexpectedly uncover potential criminal issues, and learn about the delicate balance of proactive disclosure.
  • Distinguish between voluntary disclosure and its limitations once an audit has commenced.

This course provides essential insights for legal and financial professionals, equipping you with the knowledge to strategically advise clients and effectively manage civil tax controversies.

Your Instructor

Michael J. DeBlis III, Esq.
Michael J. DeBlis III, Esq.

Trial, entertainment law and U.S. international tax law

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Michael is a partner in the boutique law firm of DeBlis Law where he specializes in tax compliance and entertainment law. Michael graduated from Western Michigan University School of Law in 2007 and later went on to earn his Masters of Law in taxation (LL.M.) from Thomas Jefferson School of Law in 2012. As a former public defender, Michael has spent nearly eight years cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of federal taxation make him uniquely qualified to handle any white-collar case, no matter how sophisticated it might be. Michael is known for his creativity, his charismatic personality, and his unyielding dedication to his clients. As a graduate of the National Criminal Defense College, Michael has trained under some of the best known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case. To that end, Michael attempts to understand each client’s case as a convincing narrative, not just as a set of innocuous facts and arcane legal rules. When he's not in the courtroom, you can find Michael on stage. As a professionally trained actor, Michael's passionate about helping trial lawyers harness the power of persuasion and positive communication in the courtroom in order to connect to the jury on a human level. Michael's training as an actor allows him to combine a unique blend of left-brain thinking with right brain artistry to make even the most dull and abstract areas of the law come to life. This burst of creativity has contributed to Michael's success as a distinguished author and sought-out speaker. Michael has written articles that have been published in leading tax journals, such as "CCH Journal of Tax Practice and Procedure," "EA Journal," "Global Tax Weekly," and "ABA News Quarterly" and is a columnist for "Law360." He has been featured on the media affiliates of several major media networks, including NBC, ABC, CBS, Fox, and CNN. Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey's rising stars of the legal profession.

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We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.