Dear Colleagues,
I am pleased to announce that I will be speaking at the upcoming BARBRI/Strafford webinar on , onSeptember 24, 2026, At 10:00 A.M. Pacific / 1:00 P.M. Eastern, Format: Live Webinar with Live Q&A (90 Minutes)
This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign international information reporting forms (including tax and FBAR filings), their associated penalties, and FBAR the process of administratively requesting abatement requests of penalties. The panel will offer useful tools for compiling and submitting the appeal correspondence and documentation
The IRS continues to aggressively enforce FBAR and foreign information reporting requirements, often asserting significant penalties. This presentation will provide practical guidance on appealing IRS denials of penalty abatement requests, developing persuasive reasonable cause arguments, navigating the IRS Independent Office of Appeals, and effectively presenting the legal and factual evidence necessary to maximize the likelihood of a successful outcome.
If your practice involves international tax compliance, IRS controversy, foreign information reporting, or tax procedure, I hope you will find this program informative and immediately applicable to your practice.
Registration is available through the following link: https://www.barbri.com/course/professional-development/CLE-CPE/appealing-irs-penalty-abatement-denials-foreign-disclosure-p_2026-09-24
Zaher Fallahi, Attorney At Law, CPA (CA & DC)