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IRS Nonfiler Representation: Handling Unfiled Tax Returns, Penalties & Compliance

October 23, 2025
60 Mins
Adam Fayne
$179.00
$249.00
$249.00
$299.00
$249.00
$179.00
$249.00
$179.00
$179.00
$249.00
$249.00
$179.00

This program will focus on representing taxpayers that have not filed tax returns.  We will discuss unfiled returns by individuals and entities.  This program will discuss how to address unfiled income tax returns, employment tax returns, Foreign Bank Account Reports, and other domestic and foreign information returns.  We will discuss best practice when representing taxpayer with unfiled returns, including how many years or periods to file, what disclosures to include, whether there are voluntary disclosure programs available, and how to minimize or abate penalties.

Webinar Objectives

This program will provide insight and tools to assist you and your clients understand the various ways to address unfiled returns.  You will learn how to prepare and file a reasonable cause statement with the unfiled returns to try and avoid penalties.  You will also learn how to try and abate penalties due to the taxpayer’s unfiled and late returns.  We will also discuss how to address unfiled returns during audits, collections, and criminal investigations. 

Webinar Highlights
  • The available processes to file unfiled returns
  • Contesting penalties assessed or proposed related to the unfiled returns
  • How to put forth a reasonable cause defense to penalties
  • Civil versus criminal risk with unfiled returns
  • How to address unfiled domestic and foreign information returns
Who Should Attend?

Accountants, tax preparers, CFOs, financial compliance professionals, and lawyers

Adam Fayne

Adam Fayne

Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money laundering and offshore tax compliance. Adam's knowledge of tax law is informed by his former role as a Special Assistant U.S. Attorney with the Department of Treasury's IRS.
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