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.

Learning Objectives:
- Understand how to request audit reconsideration
- Identify when is it 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

Program Number: 15UFN-T-00249-22-O
Credits: up to 2 hours CE / CPE available