Challenging Assessed Taxes: Audit reconsiderations, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing (Presented by Tax Rep)

Eric L. Green
Eric L. Green | Green & Sklarz, LLC.

Eric is a managing partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services.

On-Demand: September 18, 2025

1 hour CLE

Tuition: $395.00
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Program Summary

With the challenges of staffing and the pandemic, the IRS has increased its use of automation, including the automated under reporter and automated substitute for returns. Many of these proposed assessments either go unchallenged by taxpayers or, when documents are submitted, they are ignored by the IRS, leading to bad assessments and enforcement against taxpayers. This program will explain the opportunities for practitioners to reopen assessed tax liabilities, including audit reconsideration, doubt-as-to-liability offers, amending tax returns, and challenging the assessment at a CDP hearing. The program will explain each option and when practitioners should consider utilizing each of them.

Key topics to be discussed:

  • Understand how to request audit reconsideration
  • Identify when it is possible to use an amended return to reopen a bad assessment
  • Explain how Doubt-as-to-Liability Offers work
  • Understand how to utilize a CDP hearing to force a reconsideration of a tax liability
  • Describe how to use refund requests to reopen a bad assessment

This course is co-sponsored with myLawCLE.

Closed-captioning available

Speakers

Speaker_Eric L. GreenEric L. Green | Green & Sklarz, LLC.

Eric is a managing partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services. He is a frequent lecturer on tax topics for many national organizations, including Insightful Accountant, CCH, the NAEA, the NATP, the ABA Tax Section and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He was the author and lecturer of the University of Connecticut School of Business IRS Representation Certificate Program, and has served as a columnist for CCH’s Journal of Practice & Procedure. He is the founder of Tax Rep LLC which coaches accountants and attorneys on building their own IRS Representation practices, and is the host of the weekly Tax Rep Network Podcast.

Mr. Green is the author of The Accountant’s Guide to IRS Collection, The Accountant’s Guide to Resolving Tax Debts, The Accountant’s Guide to Resolving Payroll Tax Debts and The Insider’s Guide to Offers-in-Compromise.

Agenda

I. Understand how to request audit reconsideration | 3:00pm – 3:05pm

II. Identify when it is possible to use an amended return to reopen a bad assessment | 3:05pm – 3:15pm

III. Explain how Doubt-as-to-Liability Offers work | 3:15pm – 3:30pm

IV. Understand how to utilize a CDP hearing to force a reconsideration of a tax liability | 3:30pm – 3:45pm

V. Describe how to use refund requests to reopen a bad assessment | 3:45pm – 4:00pm

Credits

Alaska

Approved for CLE Credits
1 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for Self-Study Credits
1 General

Arkansas

Approved for CLE Credits
1 General

Arizona

Approved for CLE Credits
1 General

California

Approved for CLE Credits
1 General

Colorado

Pending CLE Approval
1 General

Connecticut

Approved for CLE Credits
1 General

District of Columbia

No MCLE Required
1 CLE Hour(s)

Delaware

Pending CLE Approval
1 General

Florida

Approved via Attorney Submission
1 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Pending CLE Approval
1 General

Hawaii

Approved for CLE Credits
1.2 General

Iowa

Pending CLE Approval
1 General

Idaho

Pending CLE Approval
1 General

Illinois

Approved for Self-Study Credits
1 General

Indiana

Pending CLE Approval
1 General

Kansas

Pending CLE Approval
1 Substantive

Kentucky

Pending CLE Approval
1 General

Louisiana

Pending CLE Approval
1 General

Massachusetts

No MCLE Required
1 CLE Hour(s)

Maryland

No MCLE Required
1 CLE Hour(s)

Maine

Pending CLE Approval
1 General

Michigan

No MCLE Required
1 CLE Hour(s)

Minnesota

Approved for Self-Study Credits
1 General

Missouri

Approved for Self-Study Credits
1.2 General

Mississippi

Pending CLE Approval
1 General

Montana

Pending CLE Approval
1 General

North Carolina

Pending CLE Approval
1 General

North Dakota

Approved for CLE Credits
1 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
1 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
60 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
1.2 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
1 General

Nevada

Pending CLE Approval
1 General

New York

Approved for CLE Credits
1.2 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for Self-Study Credits
1 General

Oklahoma

Pending CLE Approval
1 General

Oregon

Pending CLE Approval
1 General

Pennsylvania

Approved for Self-Study Credits
1 General

Rhode Island

Pending CLE Approval
1 General

South Carolina

Pending CLE Approval
1 General

South Dakota

No MCLE Required
1 CLE Hour(s)

Tennessee

Approved for Self-Study Credits
1 General

Texas

Approved for CLE Credits
1 General

Utah

Pending CLE Approval
1 General

Virginia

Not Eligible
1 General Hours

Vermont

Approved for CLE Credits
1 General

Washington

Approved via Attorney Submission
1 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Pending CLE Approval
1 General

West Virginia

Pending CLE Approval
1.2 General

Wyoming

Pending CLE Approval
1 General

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