10/16/2026
Collection Due Process: Navigating Liability Challenges and Collection Disputes. October 20. Easy Registration: https://sfvba.org/?pg=events&evAction=showDetail&eid=355649&evSubAction=viewMonth&calmonth=202610.
Presented by Jonathan T. Amitrano, Esq. of Taylor Nelson Amitrano LLP. Collection Due Process (CDP) hearings provide taxpayers with a critical opportunity to obtain independent review of IRS collection actions and, in appropriate circumstances, to challenge the underlying tax liability itself. This program will examine the statutory and procedural framework governing CDP hearings under IRC §§ 6320 and 6330, with particular attention to the limitations imposed by § 6330(c)(2)(B) on post-assessment liability challenges. The program will address what constitutes a prior “opportunity to dispute” a liability, the issues that may be raised before IRS Appeals, the standards and scope of judicial review, and strategic considerations for practitioners seeking to preserve and litigate liability and collection issues in the CDP context.
