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Courses/Law/Tax Law

Anatomy of a Civil Tax Controversy (Part 2)

Navigate the complex landscape of civil tax controversies, from audit to litigation, and master strategies for effective client representation and dispute resolution.

Created byMichael J. DeBlis III, Esq.
BeginnerUpdated Sep 17, 2025
Anatomy of a Civil Tax Controversy (Part 2)

What You'll Learn

check_circleUnderstand the IRS audit and determination process.
check_circleDifferentiate between 30-day and 90-day letters.
check_circleLearn strategies for appealing IRS decisions.
check_circleIdentify procedures for tax court petitions.
check_circleRecognize the impact of tax assessments and liens.
check_circleGrasp concepts of eggshell audits and voluntary disclosure.

About This Course

Delve into the intricate world of civil tax controversies with "Anatomy of a Civil Tax Controversy Part 2," a comprehensive course building on Part 1's foundational knowledge. Led by an experienced tax attorney, this course guides you through critical stages of a tax dispute, beyond the initial audit process.

  • Understand the significance of the 30-day letter and the strategic decisions taxpayers face, including requesting an IRS Appeals conference.
  • Explore the Notice of Deficiency (90-day letter), its implications, and the taxpayer's options: paying the asserted deficiency or petitioning the U.S. Tax Court.
  • Gain insights into the unique nature of the U.S. Tax Court, the role of IRS Chief Counsel, and the advantages of seeking out-of-court settlements.
  • Learn about the assessment process, its consequences, and the IRS's collection actions, including liens and levies.
  • Crucially, the course examines "eggshell audits," where potential criminal tax issues arise, emphasizing the practitioner's role in damage control and the nuances of voluntary disclosure.
  • Discover the critical element of willfulness in tax evasion, "badges of fraud," and the controversial "willful blindness" theory.
  • Master strategies for managing contact between agents and taxpayers, auditing the agent through FOIA requests and third-party summonses, and handling a "quiet" civil audit.
  • Finally, the course looks at the criminal tax enforcement system, factors driving DOJ tax prosecutions, and methods to potentially reduce tax deficiency numbers to avoid criminal charges, including the vital role of forensic accountants and "Kovel agreements."

This course offers invaluable guidance for legal and financial professionals navigating the complexities of civil tax disputes and potential criminal implications, equipping you with the knowledge to protect your clients effectively.

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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star736 reviews

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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