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Internal Revenue Service: Practice and Procedure Deskbook (4th Edition)

 
Author(s): Erin M. Collins, Edward M. Robbins, Jr.
Practice Area: Tax
Date: May 2010 i Previous editions(s) can be found in the Related Items tab.
ISBN: 9781402413384
PLI Item #: 20805

“Navigating the complex maze of IRS practice and procedure rules can be daunting — but the task is made much easier with help from two of the most experienced tax controversy attorneys in the business today.”
– Kendall Jones, Sutherland

Internal Revenue Service: Practice and Procedure Deskbook provides the thorough legal, procedural, and strategic information attorneys, accountants and other tax professionals need to represent clients more effectively when dealing with the IRS, including guidance on:

  • Examinations — including how to deal with IRS document requests, narrow the scope of IRS audits, and reach settlements as part of a correspondence, office or field examination
  • Large Business & International Division Examinations — from how to prepare for LB&I examinations to how to use IRS programs to expedite resolutions
  • Assessments — with clear coverage of IRS assessment procedures and the Code’s complex mitigation provisions
  • Civil Penalties — including steps you can take to abate penalties and minimize the risk of particular penalties being asserted, as well as, a chart containing a detailed summary of the numerous civil penalties listed by Code section
  • Tax Fraud — with details on how to make voluntary disclosures to avoid investigations, assemble defense teams, and deploy “good faith” and other defenses
  • Appeals — including how to proceed effectively in appeals conferences, as opposed to examinations, and pick the right settlement options for each client
  • Litigation — with guidance on how to select the most favorable judicial forum for each case and cope with the Tax Court’s unique rules of practice and procedure
  • Collections — from Collection Due Process hearings to surefire solutions to clients’ collection problems
Internal Revenue Service Practice and Procedure Deskbook offers analysis of key Tax Court decisions and other case law, and highlighted “Practice Pointers” and other tips for successfully representing clients in IRS dealings.
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Erin M. Collins is the Managing Director of a multi-national accounting firm’s Tax Controversy Services practice for the Western Area. Previously, Erin was a Special Trial Attorney with IRS Western Regional Counsel. She was responsible for the development and litigation of high profile, and complex tax cases. In 1995, and again in 1997, she received Chief Counsel’s highest award, the National Litigation Award, and in 1993 received the Western Region’s highest Litigation Award for her outstanding achievements. She has represented clients in federal examinations and IRS appeals on domestic and international tax issues. Erin has wide-ranging experience with alternative dispute resolution procedures in resolving difficult or uncertain federal tax issues. Erin has represented a number of clients before the U.S. Tax Court and has represented the government in several significant and complex tax cases.


Edward M. Robbins, Jr. is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. He maintains an active practice before the U.S. Tax Court, the Federal District Courts in California, Hawaii, Washington D.C. and various Federal Circuit Courts of Appeals and the California State Courts. He frequently appears before the IRS, the California Franchise Tax Board and the California State Board of Equalization. Mr. Robbins is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. Mr. Robbins’ tax practice includes a wide array of substantive areas, including income taxes, estate taxes, employment taxes, excise taxes, and sales taxes. He has received an “A-V” rating from Martindale-Hubbell. In addition to his civil tax practice, Mr. Robbins has an active practice in the criminal tax field, representing clients in the Federal and State courts, grand jury proceedings and before the IRS Criminal Investigation Division  and Department of Justice Tax Division. Prior to 2004, for eleven years as Chief of the Tax Division of the United States Attorney’s Office for the Central District of California, Mr. Robbins, in addition to his individual litigation duties, was responsible for the management and coordination of the Tax Division’s civil and criminal tax cases and supervised the Special AUSA’s in bankruptcy matters and worked with the Assistant Attorney General (Tax) and her staff to develop and ensure uniform national tax policy. Mr. Robbins was a trial attorney with the IRS office of Chief Counsel from 1978 to 1983, and from 1983 to 1993 he was an Assistant United States Attorney with the Tax Division.