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Courses/Law/Tax Law

Anatomy of a Civil Tax Controversy Part 5

Navigate the intricate appeals process and explore strategies for resolving disputes with the IRS, from payment plans to offers in compromise, ensuring you understand your rights.

Created byMichael J. DeBlis III, Esq.
BeginnerUpdated Sep 17, 2025
Anatomy of a Civil Tax Controversy Part 5

What You'll Learn

check_circleDiscern the core function of IRS Appeals within tax controversies.
check_circleIdentify how IRS Appeals mediates disputes, avoiding Tax Court.
check_circleUnderstand the processes for initiating an IRS Appeal.
check_circleDifferentiate between non-docketed and docketed tax cases.
check_circleAnalyze the impact of the 1998 Restructuring Act on appeals.
check_circleRecognize the different IRS collection methods and their implications.

About This Course

Dive deep into "Anatomy of a Civil Tax Controversy Part 5," an essential course for understanding the intricacies of IRS appeals and post-assessment remedies. This session meticulously covers the IRS appeals process, from its origin in the 1998 Restructuring Act to its role in mediating disputes between taxpayers and the IRS.

  • Explore the concept of a "deficiency" and the critical 30-day protest window for disputing a Revenue Agent's Report.
  • Learn about the Notice of Deficiency (90-day letter) and the subsequent path to U.S. Tax Court, including who can represent taxpayers in this forum.
  • Understand the commitment and expectations between IRS Appeals and taxpayers, focusing on informal administrative processes and conferencing options.
  • Examine the role of the Appeals Team Manager and the procedures for reaching an agreement, covering payment options like installment agreements and Offers in Compromise.
  • Grasp the critical differences and implications of "non-docketed" versus "docketed" cases in Tax Court.
  • Delve into IRS collection methods, including levy actions, federal tax liens, and the suspension of collection during appeals.
  • Gain practical insights into navigating tax disputes, ensuring due process, and effectively advocating for clients, even within the system's inherent challenges.

This course equips you with the knowledge to strategically manage tax controversies, ensuring you are well-prepared for every stage of the process.

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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