July 2024 Agostino Journal

II. Overview of the CAP Process
A. Appealable Actions Under CAP
1. Notice of Federal Tax Lien (NFTL)–filed or proposed
2. Levy taken or proposed
3. Seizure of property
4. Rejection, modification or termination of an installment agreement
FILING THE IRS FORM 9423–COLLECTION APPEAL
REQUEST–BEST PRACTICES by Frank Agostino, Esq.,
Yiwei Chen, J.D., and Shan Kadkoy, Esq.
FORM 9423 ANALYSIS
COLLECTION APPEALS PROGRAM (CAP) APPEAL
COVER LETTER
FILING THE IRS FORM
9423–COLLECTION
APPEAL REQUEST–
BEST PRACTICES

September 2023 Agostino Journal

Best Practices for Contesting IRS Form Payee States and Third-Party Information Reports
by Frank Agostino, Esq. and Yiwei Chen

Exhibit A- Sample Letter to Issuer Requesting CORRECTED Form
Exhibit B- Sample Letter To The IRS Reposting an Incorrect Payee Statement
Exhibit C- Sample Disclosure Statement
Exhibit D- Sample Response to IRS Notices

Written Examination Information
2023 Tax Controversy Seminar Series
2023 Practice Exam
Joining the Google Group

Interpreting and Responding to IRS Notices, and How to Use the IRS Online Services 22

May 2023 Agostino Journal

The Taxation of Performing Artists, Showbiz, and the Entertainment Industry
by Frank Agostino, Esq., Young H. Kim. Esq., and
Byung Hyuk (Billy) Min, Esq.

Challenging Form K-1, Steps to Take When Inconsistencies Arise
by Frank Agostino, Esq., Matthew Rego, Esq., and Giorgi Tsitsuashvili, LLM

April 2023 Agostino Journal

FAQ’s Re: Ukrainian Refugees
by Frank Agostino, Esq., Vakhtang Lobzhanidze, LL.M., and Giorgi Tsitsuashvili, LL.M.

The Taxation of Non-resident and Resident Aliens by Frank Agostino, Esq., and Matthew Rego, Esq.

Best Practices for Challenging IRS Forms Required
Under IRC Section 6722
by Frank Agostino, Esq., Vakhtang Lobzhanidze, LL.M., and Giorgi Tsitsuashvili, LL.M.

Tax Compliance for Recent Immigrants

Substantiating Deductions Seminar at BCC

March 2023 Agostino Journal

Extension of Time for Payment of Tax Due to Undue Hardship: “How to Prepare IRS Form 1127”
by Frank Agostino, Esq., Young Kim, Esq., and Yiwei Chen, J.D.

The Role of Hypotheticals in the USPAP’s “Highest and Best Use”
by Frank Agostino, Esq., and Billy Min, Esq.

October 2022 Agostino Journal

IRC § 6015 – HOW TO PREPARE FORM 8857 – REQUEST FOR INNOCENT SPOUSE RELIEF

By Frank Agostino, Esq. and Matthew Rego, Esq.

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