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      Tax Freedom Institute
Daniel J. Pilla


 Taxpayers Defense Conferences - Solving IRS Problems

The Nation's Top IRS Seminar for Tax Professionals


Over 25 years of

Taxpayer Defense Conferences!


2020 Taxpayers Defense Conference

Theme: Roadmap to Tax Resolution


Monday & Tuesday - October 26-27, 2020

 Luxor Hotel and Casino
Las Vegas NV

and new this year

Available virtual 
for those who prefer not to travel!

14 Continuing Educational Credits (including 2 ethics)

available for all Tax Pros through

and Minnesoata Board of Legal Education

$795 Attending Onsite
-includes lunch each day and live networking opportunities
(Does not include other meals, lodging or transportation)

Limited discounted room pricing
for reservations before Sept 25, 2020

Click here for Lodging Reservations 

$795 Attending Virtually

Special for either registration
$100 off -$695 if register before 9/15/20

2020 Theme
Roadmap to Tax Resolution

The following sessions are to be presented at the 2020 Taxpayers Defense Conference           

The Broken IRS
This session addresses the current condition of the IRS in light of COVID-19 shut downs and force reduction. Focus will be on work-arounds when dealing with the Collection and Appeals functions.

Holistic Tax Resolution Strategy 
This session presents a broad, holistic “systems engineering” approach to tax resolution. Using checklists and flowcharts, we analyze all the essential “issue spotting” considerations to review when a new client comes in.

Emergency Measures to Stop Collection
This session identifies and explains the three emergency measures to stop enforced collection. This session includes an analysis of the statutory levy exemptions and how to assert them. This session also includes a discussion of claiming a refund for wrongfully levied property. 

Understanding the Tax Court
This session reviews the fundamentals of the U.S. Tax Court. Special emphasis is on Tax Court jurisdiction so practitioners fully understand the scope of cases subject to review by the U.S. Tax Court. This session is essential even for non-attorneys, since non-attorney practitioners regularly encounter situations in which Tax Court is a resolution option that must be recognized. In that case, non-attorneys must be prepared to bring in counsel admitted to practice in the Tax Court.

Appealing a Notice of Deficiency
This session addresses the specific procedures for challenging a Notice of Deficiency, which is the IRS’s final administrative determination that a citizen owes additional taxes. The session addresses the two specific options for judicial review of the Notice of Deficiency and builds on issues presented in the session Understanding the Tax Court.

Appealing a Notice of Determination
This session addresses the statutory procedures for challenging a Notice of Determination, which is the final determination that is issued by the IRS’s Office of Appeals in a Collection Due Process Appeal. It outlines the procedures for judicial review of a Notice of Determination and this session builds on issues presented in the sessions Understanding the Tax Court and Appealing a Notice of Deficiency.

Live Role-playing of Appeal Scenarios
During this session the attendees are broken into separate groups and each group is presented with a set of facts regarding a hypothetical case involving the topics presented. All the facts are derived from actual cases. The groups must develop/present arguments to defend the taxpayer and assert a potential defense based on the facts and applicable law of the case based on all the teachings of the previous day’s sessions. Each group includes an experienced tax pro playing the part of an IRS officer.

Evaluation and Critique of Role-playing Sessions
Dan Pilla and other TFI staff review, critique and analyze each of the mock negotiation sessions. We analyze the strengths and weaknesses of each presentation, evaluate the performance of the participants, and discuss potential alternative approaches under the circumstances.

Tax Court Practice Basics
This session presents the basics of Tax Court practice and procedure, including motions practice, discovery procedures, summary judgment and remand, stipulations and agreed settlement procedures.

Understanding and Avoiding Conflicts of Interest
This session addresses essential considerations for avoiding conflicts of interest. Special emphasis will be placed on potential and actual husband/wife conflicts and conflicts arising from corporation tax issues, including especially the Trust Fund Recovery Penalty. Here we also address the Tax Court Rules of Practice regarding the process of avoiding conflicts of interest.

Ascertaining “Reasonable Fees”
This session addresses the ethical considerations encompassed in the professional responsibility to charge fees for services that are “reasonable.” Specifically, we address IRS Circular 230 governing the practice before the IRS of attorneys, CPAs and Enrolled Agents as it relates to the charging fees.

Moderated Discussion
Group discussion of problems, questions and strategies based upon all earlier presentations. We will present and discuss hypothetical cases involving various aspects of IRS problems resolution.


$795 Attending Onsite
-includes lunch each day and live networking opportunities
(Does not include other meals, lodging or transportation)

Limited discounted room pricing
for reservations before Sept 25, 2020

Click here for Lodging Reservations 

$795 Attending Virtually

Special for either registration
$100 off -$695 if register before 9/15/20


MISSED Prior Conferences?

AUDIO recordings available!

Click here for prior Taxpayers Defense Conference information.


Taxpayers Defense Conferences

Each year since 1993, Tax Freedom Institute founder and Executive Director, Daniel J. Pilla has presented the nation’s leading seminar for tax professionals, the Taxpayers Defense Conference. Designed specifically for tax pros in the business of helping taxpayers solve IRS audit, appeal and collection problems, Dan reveals the latest on exactly what to expect from the IRS and exactly how you can best help your clients weather the latest storm. To serve your clients in the best possible way, you need to know how to protect and defend your clients. That’s where the Taxpayers Defense Conference comes in.




Each year, Dan Pilla personally prepares the presentation topics for the Defense Conference. His topics always include the latest trends in IRS enforcement actions, court decisions, tax legislation and clients’ needs. Here is just a small sampling of some of our prior topics:

  • Dealing with IRS Correspondence
  • Audit-proofing and Penalty-proofing Strategies
  • Canceling Penalties and Interest
  • Handling Correspondence Audits and Face-to-face Meetings with Revenue Agents
  • Audit Appeal Procedures
  • Petitioning the Tax Court in Audit Cases
  • Negotiating with the Appeals Office and IRS Counsel
  • Understanding and Minimizing Liens, Levies and Seizures
  • Negotiating with Revenue Officers
  • Utilizing the Office of the Taxpayer Advocate
  • Negotiating Installment Agreements, Offers in Compromise, Uncollectible Status
  • Negotiating Innocent Spouse Claims
  • Collection Due Process Appeals
  • Tax Court Collection Due Process Cases
  • Understanding the Collection Statute Expiration Date
  • Claims for Refund
  • Professional Responsibility
  • Recovering Professional Fees and Costs.
  • Networking with Some of the Nation’s Most Experienced Attorneys and Accountants

Taxpayers Defense Conference Special Features

In addition to the cutting-edge topics that place and keep you ahead of the curve when it comes to defending your clients before the IRS, the Taxpayers Defense Conference also features:

  • Live interactive brain storming sessions with some of the nation’s most experienced Attorneys, CPAs and Enrolled Agents. Bring your problem cases to the Defense Conference and return to work with renewed ideas and energy.
  • Up to 50 pages of written outline material that includes tax code sections, regulation, Internal Revenue Manual references, court decisions and other legal authority. This material is unique in its organization and invaluable as future reference material. You will not want to throw it away. In addition, you get our Master Index of all prior Defense Conference topics. All of our prior seminars are available for purchase on CDs.
  • Continuing education credits for every conference, often including ethics credits, on topics that are important to your practice and your clients. You’ll waste no time at the Taxpayers Defense Conference.  
  • Networking with Tax Freedom Institute members from around the nation, and personal interaction with Dan Pilla at the conference.
Our two-day conference is widely regarded as simply the best tax seminar in the nation for those practicing in the areas of taxpayers’ rights issues and IRS problems resolution. If you are looking for information on how to prepare tax returns, this conference is not for you. But you want to get and stay on the cutting edge of taxpayers’ rights issues and need to know more about how to represent and protect your clients in IRS enforcement situations, there just is no better place in the country to do so than at the Taxpayers Defense Conference.


You Benefit from Dan’s Experience

Admitted to practice for the United States Tax Court, a Tax Litigation Consultant and author of 13 books, dozens of research reports, and hundreds of articles on IRS defense strategies, Daniel J. Pilla has been on the cutting edge of taxpayers’ rights defense for over three decades. He was a consultant to the National Commission on Restructuring the IRS. His book, The IRS Problem Solver, was ranked by the Wall Street Journal as the number one tax book in America. Simply put, nobody has more experience in handling the IRS – and never has that experience been more important than in our current tax enforcement environment. The Associated Press said, “Pilla probably knows more about the IRS than the commissioner.”

Dan’s uses his unmatched skills in research, writing and teaching to present two days worth of live sessions on the latest laws, procedures and strategies that affect how you deal with the IRS in problems resolution cases. For years, the Taxpayers Defense Conference has been sought after by attorneys, CPAs, Enrolled Agents, tax preparers and others in the tax and financial world, precisely because there is simply no place else in America to get the kind of information that’s presented by Dan in the Taxpayers Defense Conference. 

Read What Others Say About These Conferences

The Taxpayers Defense Conference is so unique and powerful in its ability to help you help your clients, it’s no wonder that more than 97% of the tax pros who’ve attended our seminar in the past say they would come back again.    In fact, many tax pros have attended this conference for more than 20 years in a row. How many seminars can you say that about?


The Taxpayer Defense Conference is what I wait for all year.  If you’ve been to one, you know what I’m talking about—THE BEST TAXPAYER DEFENSE CONFERENCE IN THE WORLD!  I know that most of you have attended many hours of continuing professional education in your career.  And I would bet the word that best describes the majority of CPE you’ve attended is . . . BORING.  The TFI Defense Conference is definitely NOT boring.  It’s not a bunch of stuffy egghead law professors and sleepy accountants droning on about esoteric crap that might affect less than 1% of your clients.  The TFI Conference is a hands on participation event that teaches you the best and most effective methods for solving IRS issues we deal with every day.  This year’s conference theme, “Installment Agreement Negotiations”, will be no exception.  Negotiating installment agreements is a very important part of most of our businesses.  The hands-on role-playing we will do on Tuesday of the Conference will definitely help us to effectively deal with the toughest Revenue Officers and Appeals Officers.  If you’re new to TFI, you should definitely attend.  You will meet folks who’ve been fighting the IRS for decades and winning, and you will leave the conference with a LOT of practical tools that will boost your business and please your clients.

    Paul R Tom- Attorney

After reading this year's (2015) agenda which focuses on Offers in Compromise, I think this could be the best Defense Conference ever.  Offers are a big part of my practice and I have had tremendous success with them in the last few years.  They are an incredibly valuable tool.

Dan is bringing back the role-playing sessions he introduced last year when he concentrated on CDPs.  He put the attendees in groups and gave them different CDP problem cases.  They each argued their case in front of a Settlement Officer.  Dan then went over each scenario and everyone in the room discussed the case and how to win it.  This year, he is putting together some of the biggest objections brought up by the IRS in OIC cases.
I can guarantee you the following:
        1.  No matter how much you think you know about Offers, Dan will dissect the IRM and present tools, tips, and tricks you do not know.
        2.  You will have more Offers accepted this year than last.
        3.  More accepted Offers means higher fees.
        4.  When the role-playing session is done, you will know how to solve the toughest OIC cases.
        5.  The brainstorming sessions are gold and not just limited to Offers.  Bring your toughest case and it will be solved.
        6.  You will network with highly skilled tax professionals who do not think you are strange because you find that dealing with
                and fighting the IRS is interesting and fun.
        7.  You will leave the Conference pumped up and at the top of your game.
        8.  You will love the little desserts at the free buffet lunches.
If you have never been to the Defense Conference, this is the year.   
         Steve Klitzner - Attorney



“If you can attend just one seminar this year, make it the Taxpayers Defense Conference. It’s the best tax controversy conference in the U.S. There’s nobody better than Dan Pilla.”           Tommy S. – Attorney

“If you’ve not attended, you’re missing the best opportunity you have to network with the best in the country. As far as I’m concerned, it’s a must.   Leo S. – CPA

“This event is a ‘must attend’ for even the most experienced tax practitioners. Dan has the inside track on the latest IRS policy and procedural changes. He’s a walking encyclopedia on IRS procedures. His written material is well-organized and provides an excellent resource for future reference.”      Don M. – Attorney

“I’ve attended your conferences for the last ten years. I’m always impressed with the quality of your presentation. I cannot get this information from any other source. I appreciate your tireless preparation each year."     Judy J. – Enrolled Agent

“The Taxpayers Defense Conference exceeded my expectations as far as useful and informative information and outlines. The information will substantially assist me in my dealings with the IRS on behalf of my clients.”     Jim C. – Attorney

“This conference is cutting-edge taxpayer defense advice from the best in the country. There’s no better tax seminar on the planet. I’ve only missed one in the last 17 years. Don’t miss the opportunity to brainstorm with the best tax pros in the business. Paul T. – Attorney


Don't Miss 2020!  

Prior Conferences 

 Click here for Taxpayers Defense Conferences Details and Audio Sets

 You can also call to order prior years audio outline sets  (2006 on) for just $149 per year plus $10 shipping. 
Sets include  USB MP3s audio of sessions and outlines, no CE.
Call 1 800 346-6829 to order!


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