IRS Nonfiler Representation: Handling Unfiled Tax Returns, Penalties & Compliance

Adam Fayne

Adam Fayne

Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white-collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money...
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October 23, 2025
01:00 PM ET | 12:00 PM CT
60 Mins

Representing Taxpayers Who Have Not Filed Tax Returns

This program, by tax attorney Adam S. Fayne, will focus on representing taxpayers who have not filed tax returns.  Adam will discuss unfiled returns by individuals and entities. This program will discuss how to address unfiled income tax returns, employment tax returns, Foreign Bank Account Reports, and other domestic and foreign information returns. 

Adam will discuss best practices when representing taxpayers with unfiled returns, including how many years or periods to file, what disclosures to include, whether there are voluntary disclosure programs available, and how to minimize or abate penalties.

Webinar Objectives

  • This program will provide insight and tools to assist you and your clients in understanding the various ways to address unfiled returns. 
  • Attendees will learn how to prepare and file a reasonable cause statement with the unfiled returns to try to avoid penalties.  
  • Attendees will also learn how to try to abate penalties due to the taxpayer’s unfiled and late returns. 
  • We will also discuss how to address unfiled returns during audits, collections, and criminal investigations. 

Webinar Highlights

  • The available processes for filing unfiled returns
  • Contesting penalties assessed or proposed related to the unfiled returns
  • How to put forth a reasonable cause defense to penalties
  • Civil versus criminal risk with unfiled returns
  • How to address unfiled domestic and foreign information returns

Who Should Attend

  • Accountants
  • Tax preparers
  • CFOs
  • Financial Compliance Professionals
  • Lawyers

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IRS CPE Credits: 1 Tax hour

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