Understand IRS Litigation Actions With Respect to Fraudulent Conveyances, Alter Egos and Nominees Related to Taxpayer Properties
The IRS has been becoming much more aggressive in seeking to collect from third parties who may own property on behalf of a taxpayer or who have had property conveyed to them by a delinquent taxpayer. The IRS is aggressively asserting fraudulent conveyance actions against those who have acquired property from a taxpayer for a bargain price. It is also foreclosing on properties where it believes that property is being held for the benefit of a taxpayer.
This session with expert speaker Robert McKenzie will discuss the litigation remedies available to the IRS when it believes that games are being played with respect to the ownership of property. Robert will also discuss other types of actions available to the IRS to enforce federal lien rights.
Transferee liability and nominee liens/ levies procedures
Your client’s appeal rights to transferee liability
Your client’s very limited appeal rights to nominee liens & levies
Your client’s litigation rights to reverse nominee liens/levies
IRS criteria for asserting fiduciary liability
NASBA & IRS Category of Study: Taxes
Who Should Attend
CPAs and Enrolled Agents
Finance and Accounting Professionals
Accounting and taxation firms
Law firms dealing with tax issues
Profit businesses involved in joint ventures with non-profit organizations
Robert E. McKenzie is a partner of the law firm of Saul Ewing Arnstein & Lehr LLP of Chicago, Illinois, concentrating his practice in representation before the Internal Revenue Service and state agencies. He has lectured extensively on the subject of taxation. He has presented courses before tho...