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The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil

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The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil

November 12 @ 1:50 pm - 3:30 pm PST

Kostelanetz LLP partner Michael Sardar will lead a session at the 2024 Taxpayer Representation Super Conference, hosted by the American Society of Tax Problem Solvers (ASTPS), from November 12-14, 2024, at Embassy Suites San Antonio Riverwalk. Michael’s session, “The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil,” on November 12 from 1:50 pm to 3:30 pm will focus on managing risk in large and complex IRS audits, where large adjustments are likely. He will guide attendees through strategies for preserving clients’ privileges during sensitive audits, recognizing signs that an audit could escalate to a criminal investigation and ensuring clients remain compliant with their tax reporting obligations.

The Super Conference, a three-day event dedicated to representing clients before the IRS, features 15 sessions on high-level tax resolution topics. Attendees, including practitioners who focus on criminal and civil tax matters, white-collar criminal defense and government investigations, and tax controversy, will learn about issues ranging from criminal tax investigations to tax controversy litigation.

As IRS enforcement is expected to increase in 2025, the conference provides timely insights. Other notable sessions include how to file a protest letter to appeal denied Offers in Compromise, the IRS’s use of AI in auditing high-income taxpayers, and strategies for handling cases led by newly hired IRS agents.

You can learn more about the ASTPS Super Conference and register here. While live attendance in San Antonio is currently waitlisted, virtual attendance options are still available.

Michael Sardar is an experienced tax attorney and co-chair of the Federal Bar Association’s section on taxation’s New York chapter. Michael has vast experience in IRS foreign bank and asset reporting (FBAR) requirements and the IRS Offshore Voluntary Disclosure  Program. He represents a variety of clients in civil and criminal tax investigations and prosecutions and other white-collar criminal matters in New York State and New York City.