Anatomy of a Civil Tax Controversy: Understanding the IRS Enforcement Process

Date & Time Wed, November 18, 2026

10:00 AM PST 01:00 PM EST

Duration 90 Mins

Webinar ID IQW26K1153

Level Basic

Speaker Mr.Michael DeBlis III

What you'll learn?

What are the primary steps involved in the IRS audit process, and how can taxpayers prepare for each stage?
In what ways does the Appeals process maintain its independence from the IRS compliance function, and why is this independence critical?
How do the ex parte communications rules impact the interaction between Appeals and compliance during a tax controversy?
What criteria must be met for Appeals to raise new issues during the appeals process, and why are these criteria significant?
How does the Appeals process balance the need for efficient tax collection with the taxpayer’s concerns regarding the intrusiveness of collection actions?
What are the implications for a taxpayer if an agreement is not reached during the Appeals process, particularly regarding the subsequent steps they must take?
How can taxpayers effectively raise issues during the Appeals process, and what types of issues are considered relevant by Appeals employees?
In what ways can the legal and factual hazards of litigation influence the decision-making process of Appeals employees?
What roles do the IRS Chief Counsel and Appeals team manager play in the resolution of tax controversies, and how do their responsibilities differ?
What strategies can taxpayers employ to prepare for a potential Tax Court petition following a notice of deficiency?
How does the IRS's collection methods, such as installment agreements and offers in compromise, provide options for taxpayers facing tax debts?
What lessons can be learned from the case of U.S. v. KPMG regarding the limitations of attorney-client privilege in the context of tax advice?
What are the primary steps involved in the IRS audit process, and how can taxpayers prepare for each stage?
In what ways does the Appeals process maintain its independence from the IRS compliance function, and why is this independence critical?
How do the ex parte communications rules impact the interaction between Appeals and compliance during a tax controversy?
What criteria must be met for Appeals to raise new issues during the appeals process, and why are these criteria significant?
How does the Appeals process balance the need for efficient tax collection with the taxpayer’s concerns regarding the intrusiveness of collection actions?
What are the implications for a taxpayer if an agreement is not reached during the Appeals process, particularly regarding the subsequent steps they must take?
How can taxpayers effectively raise issues during the Appeals process, and what types of issues are considered relevant by Appeals employees?
In what ways can the legal and factual hazards of litigation influence the decision-making process of Appeals employees?
What roles do the IRS Chief Counsel and Appeals team manager play in the resolution of tax controversies, and how do their responsibilities differ?
What strategies can taxpayers employ to prepare for a potential Tax Court petition following a notice of deficiency?
How does the IRS's collection methods, such as installment agreements and offers in compromise, provide options for taxpayers facing tax debts?
What lessons can be learned from the case of U.S. v. KPMG regarding the limitations of attorney-client privilege in the context of tax advice?

Overview of the webinar

There is a certain rhythm to the audit process, and it’s a very scary beat. In this presentation, I'll discuss the steps that most examinations begin and end with. We'll discuss eggshell audits, those audits where unbeknownst to the IRS at the start of the examination, the taxpayer has major criminal problems and what you can do to help shepherd your client through the pending storm. We'll also discuss the attorney-client privilege in the tax realm as well as the necessity to retain a Kovel accountant when there are underlying criminal tax issues that are lurking. Finally, we'll take a short digression into IRS Appeals.

Who should attend?

Tax Attorneys and Tax Controversy Practitioners
CPAs and Enrolled Agents
Tax Advisors and Accountants
Attorneys Representing Individuals or Businesses in IRS Matters
Professionals Involved in Audits, Collections, Penalties, Appeals, or IRS Examinations

Why should you attend?

Faculty - Mr.Michael DeBlis III

Michael is a trial lawyer. He graduated Cum Laude from The Thomas M. Cooley Law School and Summa Cum Laude from the Thomas Jefferson School of Law with his Masters of Law in Taxation. Michael is known for his charismatic personality and his unyielding dedication to his clients. Michael spent the first six years of his legal career as a public defender in the NJ Office of the Public Defender cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. He then joined his father's law practice, DeBlis Law, expanding the practice into civil tax controversies and international tax compliance.As a graduate of the National Criminal Defense College, Michael has trained under some of the best-known criminal defense attorneys in the country. When he's not in the courtroom, you can find Michael on stage. He is a professionally-trained actor who has performed in off-Broadway productions and on-stage at Shakespeare in the Park. 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. Michael is a prolific writer and a frequent lecturer at CLE and CPE programs throughout the country. He has written articles that have been featured in leading tax journals and "Law 360." 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.

Thank you for your interest in becoming a part of our faculty. GRCTutors is continuously looking for excellent individuals from diverse professions to add to our faculty records. Please complete the form below to be considered for our training arrangements in your area of expertise and then submit the form; we will get back as soon as possible.