Webinar: A Different Kind of Fresh Start: Collections and Penalties Under the TAS Act by ALFi

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Presenters

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

Terry Lemons

Director of Public Relations

From running communications and outreach for a major government agency to covering Congress and the White House as a reporter, Lemons has decades of experience inside and outside government.

During more than 26 years at the Internal Revenue Service, he played a pivotal role overseeing the tax agency’s communications and outreach efforts to taxpayers and tax professionals. His behind-the-scenes duties included advising six different IRS Commissioners, creating the IRS “Dirty Dozen” tax scams list in 2002, establishing the innovative IRS social media program as well as working closely with the tax professional and legal communities on tax compliance and taxpayer service issues.

About

Program Field of Study: Taxes | Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, Attorneys
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00033-26-O

The TAS Act would reshape IRS collections and penalty relief in ways practitioners will feel immediately. This session examines the proposed automation of refund offset bypass, elimination of installment agreement fees for certain individuals, required notice of collection alternatives for taxpayers in hardship, and quarterly reminders for those carrying a balance. We'll work through a package of offer-in-compromise reforms including streamlined Chief Counsel review, the right to appeal a returned offer, and refunds of amounts collected beyond an accepted offer—along with an extended window for taxpayers to recover wrongfully levied property. The session also includes the rewrite of § 6751(b) supervisory approval for penalties and the new failure-to-pay safe harbor for individuals who timely pay 125% of the prior year's liability. Attendees will leave able to spot which clients these tools would help and how the § 6751(b) changes reshape penalty defense.

Agenda

Identify the collection relief tools the TAS Act would create, including refund offset bypass automation and installment agreement fee elimination
Explain the proposed offer-in-compromise reforms, including appeals of returned offers and return of amounts collected beyond an accepted offer
Analyze the proposed § 6751(b) rewrite and its implications for penalty defense
Apply the proposed 125% failure-to-pay safe harbor to individual client scenarios
Describe the proposed extension of the period to recover wrongfully levied property