IRS Nationwide Tax Forum (Orlando)

Frank Agostino will speak at the IRS Nationwide Tax Forum in Orlando, Florida, being held Sept. 1-3, 2026, at the Caribe Royale Orlando.

The IRS describes its Nationwide Tax Forum as “the marquee IRS outreach event to the tax professional community. It includes a three-day event providing tax professionals with the latest information on federal and state tax issues presented by experts from the IRS and its partner organizations through a variety of training seminars and workshops. In addition to seminars, the Forum also features a two-day exhibit hall, special programs, and more.”

More information can be found here.

Frank will speak on the following panels at the Orlando Forum:

Plenary Session: Artificial Intelligence in Tax – Panel Discussion

As IRS online services expand, tax professionals need practical ways to turn raw IRS data into efficient, defensible workflows. This panel discussion explores how AI-powered tools can sit on top of IRS systems—such as Tax Pro Account, the Transcript Delivery System, and IRS Online Accounts—to retrieve, analyze, and act on taxpayer data at scale. Panelists will discuss how AI products can connect to IRS e-Services to pull and interpret transcripts, surface assessments, penalties, collection statute expiration dates (CSED), and resolution opportunities, and then draft notice responses, penalty abatement requests, and client advisory memos grounded in that IRS data. Throughout, the session emphasizes practitioner review, verification against IRS records, and Circular 230 compliance—ensuring that professional judgment is never outsourced to technology. By the end of this session, participants will be able to:

• identify how AI tools can connect to IRS e-Services and the Transcript Delivery System to retrieve and organize taxpayer transcripts automatically;
• identify key data points—assessments, penalty breakdowns, transaction codes, and CSED—that AI-driven transcript analysis can surface;
• recognize the ethical and professional obligations under Circular 230 when incorporating AI products into tax practice, including the requirement to stress-test AI outputs against authoritative sources;
• recognize the IRS's goals, vision, and challenges in integrating new technologies and IT systems; and
• Apply practitioner verification protocols to ensure that professional judgment is never outsourced to technology

Tax Issues Relating to NIL, Performers, and Influencers

This session, presented by the American Bar Association Section on Taxation, highlights the most common federal tax issues for college athletes earning Name, Image and Likeness (NIL) income, performers and digital creators/influencers. We’ll focus on how these clients get paid (cash, platform payouts, sponsorships, affiliate income and in-kind benefits), how those amounts are documented and reported, and the practical Schedule C/self-employment tax implications. The seminar also flags paid-preparer due diligence touchpoints when refundable credits (Earned Income Tax Credit (EITC) and Child Tax Credit (CTC)/Additional Child Tax Credit (ACTC)) are claimed and the preparer-penalty exposure that can follow weak documentation. By the end of this seminar, participants will be able to:

• Recognize the federal income, self-employment, and information-reporting consequences of NIL revenue-share payments, collective contracts, and non-cash benefits for student-athletes.
• Identify the operational, private-benefit, and inurement issues that drive adverse determinations on § 501(c)(3) NIL collectives under AM 2023-004 and the post-2024 PLR sequence.
• Apply the FMV workpaper, the § 162 advertising-agreement framework, and the reasonable-compensation analysis to common NIL fact patterns.
• Locate Stakeholder Liaison and Taxpayer Advocate Service resources — including the TAS NIL Hub — for client referrals and continuing-education updates.
• Spot the Tax Court pleading and procedural traps under § 7428 declaratory-judgment jurisdiction and Tax Court Rule 34(b)(4).

Tax Professional’s Guide to Preparing Tax Returns for Taxpayers with ITINs

This seminar is a practical guide for preparing federal returns for taxpayers and dependents who file with IRS individual taxpayer identification numbers (ITINs), with an emphasis on avoiding delays, rejections and notices. We’ll address common ITIN scenarios, how ITIN status affects dependent claims and credit eligibility, and what documentation tends to drive IRS questions. The session also covers paid-preparer due diligence requirements when Earned Income Tax Credit (EITC) and Child Tax Credit (CTC)/Additional Child Tax Credit (ACTC) are claimed, including the documentation mindset needed to reduce preparer penalties. By the end of this seminar, participants will be able to:

• Identify which federal tax obligations apply to an ITIN holder regardless of immigration status, and which credits are categorically unavailable.
• Apply the correct worker-classification rules to ITIN holders and recognize when an employer's use of a 1099 is a misclassification, not an immigration-status accommodation.
• Advise an S-corporation officer who lacks work authorization, applying the reasonable-compensation rule of Veterinary Surgical Consultants without invoking the limited-partnership exclusion of § 1402(a)(2).
• Identify the bright lines that separate competent practice from preparer penalty and criminal exposure when serving ITIN clients.

About Frank

During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.