IRS Admin Record: Be Proactive in Shaping and Preserving It

When:  Dec 11, 2023 from 05:00 PM to 08:00 PM (PT)

Program Overview

December 11, 2023| 5:00 pm - 8:00 pm, Pacific |In person

Hosted by San Fernando Valley

Speaker   Steven L. Jager, CPA, MST, USTCP


EA’s and CPA’s are on the front lines in shepherding our clients through the CDP Hearing Process, so it is incumbent upon us to shape, create and preserve the administrative record. It could be considered malpractice when a failure here is due to our negligence. Learn strategies, techniques, and tactics to prepare the most effective administrative record – especially for when you must hand off your case to a lawyer or USTCP to take the case to Tax Court.

  Learning Objectives

1) Learn what is the administrative record, why it is important and why we MUST care about it.
2) Understand the standard of review of a CDP case by the United States Tax Court.
3) Learn what is “abuse of discretion” and how do you give your client their best chance to highlight when the IRS has abused its discretion?
4) Identify properly raising issues during a Collection Due Process Hearing and putting these issues into the administrative record.
5) Understand the Administrative Records Rule and the “Giamelli Rule” and they intersect with each other. 
Learn why you must pay attention to the Administrative Record, no matter which party in an innocent spouse claim you are representing.

Learning Level    Basic

Prerequisites & Advance Preparation

Continuing Education

IRS:  2 hours Federal Tax Topics |   CTEC:  2 hours Federal Tax Topics   |   CA Bar:  1.75 hours Taxation Law  |  CPA CA:   2 hours Taxes


Member: $60 | Non-Member: $75 early bird pricing until 11/30/23
Member: $75 | Non-Member: $90 regular pricing from 12/1/2023 until 12/8/2023

In-Person Details

The Odyssey Restaurant
15600 Odyssey Dr.
Granada Hills, California 91344
(Registration at the door is permitted but meals will be limited to availability if not pre-registered)


  • 5:00 - 6:00: Social Networking/Dinner
  • 6:00: Education Program Begins
  • 8:00: Education Program Ends

Cancellation/Refund Policies

Please contact the host Chapter at for refund/cancellation policies related to this event.


The Odyssey Restaurant
15600 Odyssey Dr.