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Courses/Law/Tax Law

The Anatomy of a Civil Tax Controversy Part 3

Navigate the critical stages of a civil tax controversy from IRS audits and appeals to Tax Court petitions and criminal enforcement.

Created byMichael J. DeBlis III, Esq.
BeginnerUpdated Sep 17, 2025
The Anatomy of a Civil Tax Controversy Part 3

What You'll Learn

check_circleUnderstand tax audit triggers and processes.
check_circleGrasp deficiency definition and implications.
check_circleLearn IRS appeal and tax court options.
check_circleIdentify crucial tax assessment deadlines.
check_circleRecognize substantiality in tax evasion cases.
check_circleApply strategies for eggshell audit defense.

About This Course

Welcome to "The Anatomy of a Civil Tax Controversy Part 3," the third installment in our comprehensive four-part series. This course delves into critical stages of a civil tax controversy, following the initial audit and the 30-day letter discussed in previous parts. We begin by exploring the strategic considerations surrounding the 30-day letter, particularly the option to appeal to the IRS Appeals Division versus directly receiving a Notice of Deficiency.

You will gain invaluable insights into:

  • The 90-Day Letter and Tax Court Petitions: Understanding the options available upon receiving a Notice of Deficiency, including petitioning the Tax Court and the implications of this crucial 90-day window.
  • Assessment and Collections: Examining the pivotal concept of "assessment" in tax law, why it's a critical turning point, and the subsequent collection actions the IRS may take, such as liens and levies.
  • Eggshell Audits and Fraud Concerns: Learning how to identify and manage "eggshell audits" where potential fraud might be uncovered, and the essential role of the tax attorney in navigating these delicate situations, including the importance of a Covel agreement to protect attorney-client privilege.
  • DOJ Tax and Criminal Prosecution: Gaining an understanding of the Department of Justice Tax Division's role, its enforcement priorities, and the criteria for criminal tax prosecution, including the "substantiality requirement" for tax evasion. We'll also cover strategies to prevent criminal referral, such as utilizing forensic accountants to re-evaluate tax liability.

This course emphasizes the precise meaning and critical deadlines within tax law, empowering you to make informed strategic decisions. Whether you are returning to this series or new to the complexities of tax controversies, "Part 3" offers essential knowledge for effectively representing clients and navigating high-stakes tax disputes.

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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