Meetings

CTEA'S next meeting via Zoom is:

Date:  Monday, April 20, 2026

Subjects: Overview of IRS Appeals - Exam and Collection           

Speaker: John Mitchell, Attorney/Enrolled Agent 

Program Number: NX6M8-T-00162-2026-O 

Prerequisites: None

CE Credit Hours: Two

Time: 10 a.m. - noon

Overview of IRS Appeals (Exam)                                This presentation provides tax professionals with a practical overview of the IRS Independent Office of Appeals in Examination cases, focusing on how disputes move from audit to settlement. Participants will learn the statutory foundation and mission of Appeals under IRC § 7803(e), the differences between Exam and Appeals functions, eligibility and protest requirements, and how the hazards-of-litigation standard drives settlement decisions. The program also covers the structure of Appeals conferences, distinctions between docketed and non-docketed cases before the United States Tax Court, and practical strategies for preparing persuasive protests and negotiating effectively. Emphasis is placed on real-world best practices to improve outcomes and reduce the risk of unnecessary litigation.

Overview of IRS Appeals (Collection) This presentation provides tax professionals with a practical overview of Collection cases before the IRS Independent Office of Appeals, focusing on how taxpayers can challenge liens, levies, and other enforcement actions. Participants will learn the statutory framework governing Collection Due Process hearings under IRC §§ 6320 and 6330, the differences between CDP and the Collection Appeals Program (CAP), and the scope of issues that may be raised, including liability challenges, collection alternatives, and procedural verification. The program also explains the abuse-of-discretion standard applied by Appeals and the balancing test required by law, along with strategic guidance for preparing Form 12153, presenting financial information, and preserving judicial review rights before the United States Tax Court. Emphasis is placed on practical advocacy techniques to improve outcomes while protecting taxpayer rights.

John A Mitchell, LLB, MST

Tax Attorney (MX) | Enrolled Agent (IRS)

Fellow of the National Tax Practice Institute (NTPI)

United States Tax Court Practitioner (USTCP)

Former IRS Appeals Officer (Exam)

Houston, Texas |  1-800-99-Tax-Help
 

Note: Invitation to this event will be made to members through email. The email will include the meeting link. Visitors or anyone else interested in attending this meeting must email Jackie Rollins at JackieRollins02@aol.com for an invitation.