Webinar: Welcome to Tax Controversy by ALFI

ALFI

Tax controversy cases can move quickly, and the right strategy often depends on understanding where the matter stands in the lifecycle of assessment, notice, appeal, and collection. This session provides a practical roadmap for navigating IRS and Maryland tax controversies, with a focus on the procedural tools and resolution options practitioners use most often.

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Presenter

Peter Haukebo

Esq.

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

Esq.

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

Attendees will learn how to spot critical deadlines, preserve appeal rights, and assess available remedies in audit, collection, and post-assessment situations. The presentation also covers core resolution strategies such as offers in compromise, installment agreements, currently not collectible status, bankruptcy, penalty abatement, innocent spouse relief, and lien-related remedies. Designed for practitioners handling real-world disputes, this course emphasizes strategy, sequencing, and informed client counseling over theory alone.

Agenda

Identify the major stages of a tax controversy case, from assessment and notices through appeals and collection.
Differentiate among IRS and Maryland controversy procedures, including audits, Collection Due Process, and Tax Court rights.
Recognize the most common collection and resolution tools, including offers in compromise, installment agreements, currently not collectible status, bankruptcy, penalty abatement, and innocent spouse relief.
Evaluate when each resolution path is most appropriate based on the taxpayer’s facts, financial condition, and procedural posture.
Outline the key deadlines, filings, and strategic decisions that can affect a taxpayer’s ability to contest or resolve a liability.
Apply practical judgment to protect client rights, preserve appeal options, and communicate realistic outcomes in tax controversy matters.