Webinar: Freedom of Interpretation: IRS Data, Access, and Case Strategy by ALFi

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Presenters

Peter Haukebo

Partner

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.

About

Program Field of Study: Taxes, Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, tax preparers, attorneys
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00036-26-O

Obtaining the records, however, is the smaller half of the problem: account data arrives as transaction codes, module entries, and date sequences that disclose their meaning only to a reader who knows the conventions. This session examines what the IRS captures through third-party reporting and generates within its own systems, and the authorization and disclosure routes that make those records available — including how account structure, such as mirrored assessments, determines the scope a Form 2848 or 8821 must cover. It then turns to interpretation, using account transcript and tax module entries such as TC 971 action codes, together with Document 6209, the agency's public guide to transaction and account codes, to show what the record establishes about notice timing, statute computation, and the procedural history of a matter. Third-party contact requirements under the Taxpayer First Act, and the changes proposed in the pending Taxpayer Assistance and Service Act, are addressed as part of how the IRS gathers information it does not already hold.

Agenda

Identify the principal sources of taxpayer data the IRS collects and the systems in which that data is maintained
Compare the authorization and disclosure routes available for obtaining IRS records, including transcript requests and Freedom of Information Act requests
Interpret entries appearing on account transcripts and tax modules, including TC 971 action codes, and explain the conventions governing how they are recorded
Apply Document 6209 and other publicly available IRS reference materials to decode transaction, module, and account data
Evaluate information drawn from IRS records to inform case strategy, including statute computation, notice timing, and assessment of procedural posture