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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


2019 marks our 25th anniversary of 

Taxpayer Defense Conferences!


2019 Taxpayers Defense Conference

Monday & Tuesday - October 28-29, 2019

Minneapolis, Minnesota

Embassy Suites - Minneapolis Airport


Mark your calendar and
check back for more details!

2 Day Conference - Buffet lunch included both days* 

Continuing Educational Credits available for all Tax Pros 


MISSED 2018?

Audio Sets available!
Click here for More Details

2018 Taxpayer Defense Conference  

IRS's Future State with emphasis on Innocent Spouse Claims

This year's conference will focus on c
urrent enforcement initiatives announced by the IRS, including crypto-currency enforcement, areas of the Tax Cuts and Jobs Act, and special emphasis on Innocent Spouse rules. Topics will include:  

  • IRS’s Future State
  • Section 199A of the Tax Cuts and Jobs Act
  • Revocation of Passports
  • The Innocent Spouse Rules
  • Innocent Spouse Equitable Relief
  • Live Role-playing of Innocent Spouse Scenarios
  • Ethical Considerations for Entertainment Expenses


MISSED Prior Conferences?

AUDIO recordings available!

Click here for prior Taxpayers Defense Conference information.


2018 Detailed Agenda

Session 1: IRS’s Future State
Dan Pilla addresses the current enforcement initiatives announced by the IRS, with particular focus on crypto-currency enforcement. Pilla also analyzes the IRS’s new five-year strategic plan that outlines the agency’s long-term goals regarding enforcement and administration.

Session 2: Section 199A of the Tax Cuts and Jobs Act
Dan Pilla analyzes new code §199A, created under the Tax Cuts and Jobs Act. This is the section that creates the 20% deduction for small businesses and self-employed persons. It is a complex calculation and the deduction is dependent upon a number of fact considerations. Pilla provides numerous examples to illustrate the calculations and reviews the new proposed regulations issued by the IRS on this matter.

Session 3: Revocation of Passports
Dan Pilla explains the law allowing the IRS to certify certain taxpayers to the State Department as “seriously delinquent” if they owe more than $50,000. We examine what constitutes being “seriously delinquent,” the required “notice” process, what the exceptions are, and how the available appeal procedures work.

Session 4: The Innocent Spouse Rules
Dan Pilla provides a full analysis of the provisions of code §6015(b) and (c), the innocent spouse and separate spouse election rules, along with IRS Form 8379. Special emphasis is put on the burden of proof a taxpayer must carry to establish entitlement to innocent spouse relief.

Session 5: Innocent Spouse Equitable Relief
Scott MacPherson addresses code §6015(f), the so-called “equitable relief” provision under the innocent spouse rules. Separate rules apply under §6015(f) if a taxpayer does not qualify for relief under either §6015(b) or (c). This is an important provision because there is no statute of limitations on a taxpayer’s right to apply for relief under this provision, contrary to both §6015(b) and (c) 

Session 6: Live Role-playing of Innocent Spouse Scenarios
The attendees are broken into eight separate groups and each group is presented with a set of facts regarding a hypothetical innocent spouse case. All the facts are derived from actual cases. The groups must present arguments to defend the taxpayer and assert a potential innocent spouse defense based on the facts and applicable law of the case based on all the teachings of the previous day’s sessions. Each group will feature an experienced tax pro playing the part of an IRS officer.

Session 7: Evaluation and Critique of Role-playing Sessions
Dan Pilla, Scott MacPherson 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 each participant, and discuss potential alternative approaches under the circumstances.

Session 8: Ethical Considerations for Entertainment Expenses
The Tax Cuts and Jobs Act changed considerably the rules for deducting business entertainment expenses for years beginning in 2018. The narrow definition of “entertainment” expenses in §274 and its regulations raise serious ethical considerations for tax pros in the preparation of business tax returns. Pros must be aware of the applicable definitions, they must caution their clients regarding what is an “entertainment” expense (and thus non-deductible) and what is an otherwise allowable business expense (and thus fully deductible). Dan Pilla analyzes the various elements of §274, include the infamous §274(d), which carries very strict record-keeping rules for deducting business meals, travel and entertainment expenses. Tax pros must know these rules and must ensure that their clients know these rules order to, a) avoid claiming expenses that are not deductible, and b) taking the benefit of deductions that are otherwise perfectly legal.

Session 9: 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 negotiations.


 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 15 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 2018!  

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 CDs or USB MP3s audio of sessions and outlines, no CE.
Call 1 800 346-6829 to order!


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