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Defensive Tax Return Disclosures

Total Credits: 2 including 2 Taxes - Technical

Average Rating:
ACPEN Industry Institute |  ACPEN Tax Institute |  IRS Approved |  Tax
David Randall Jenkins, Ph.D.
Course Levels:
2 Hours


Defensive tax return disclosures are made on Forms 8275 or 8275R, depending on whether the declared position is consistent or inconsistent with extant treasury regulations. However, the reason for filing defensive tax return disclosures goes beyond avoiding penalties associated with intentional disregard for rules and regulations. Preempting IRS deficiency notice presumptive correctness is a dominating consideration. This webcast explains.

This webcast involves Section 179 depreciation expense at the partnership level in a startup operation. Although not incorporated into this webcast, Dr. Jenkins wants to share his paper, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships or S Corporations." The paper is currently in peer review at a university tax journal. Also, the ACPEN/BPN webcast based on this paper will be first aired during the week of September 25-29, 2017. Please be sure to look for that announcement and register for the webcast.


Lesson 1.


Lesson 2.

Forms 8725 and 8725R and Intentional Disregard of Rules and Regulation Penalties

Lesson 3.

Affirmative Equitable Defenses

Lesson 4

Preempting IRS Deficiency Notice Presumptive Correctness

Lesson 5


Basic Course Information

Learning Objectives

*Recognize important differences in correctly filing Forms 8725 and 8725R

*Recognize equitable tax doctrine application can correctly set aside black letter law targeted benefits  

*Recognize why it is important to correctly rebut the IRS presumption of correctness when filing client tax returns  

*Recognize properly prepared affidavits and incorporated exhibits amount to defensive tax return disclosures that correctly reduce IRS controversies to questions of law

Major Subjects

*Forms 8725 and 8725R  

*Penalties associated with intentional disregard of rules and regulations  

*Equitable Tax Doctrines  

*IRS deficiency notice presumptive correctness  

*Preparing defensive tax return disclosures

Course Materials


David Randall Jenkins, Ph.D.'s Profile

David Randall Jenkins, Ph.D. Related seminars and products:

David Randall Jenkins, Ph.D., received his doctorate in accounting and a master’s in accounting with an emphasis in tax from the University of Arizona. He has taught financial, managerial, and tax accounting courses at both the graduate and undergraduate levels. Dr. Jenkins is an AACSB academically qualified business school and tax professor owing to his peer reviewed journal article publications. His company, Algorithm LLC (, is an IRS Approved Continuing Education Provider.  Dr. Jenkins may be contacted at

Additional Info

Basic Course Information


This webcast is an intermediate continuing education webcast.  

It is assumed the webcast participant has achieved basic understanding of the following:   Equitable tax doctrines, Penalties associated with intentional disregard of rules and regulations, & Issues involving IRS deficiency notice presumptive correctness

Advanced Preparation


Designed For



*Enrolled Agents

*Enrolled Retirement Plan Agents

*Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators  

*Self-directed Retirement Plan Account Holders

*Tax Return Preparers    

Original Recording Date


Yellow Book


Course Developer

David Randall Jenkins

Date Added to Catalog


Additional Information

Complaint Resolution Policy

Please contact Anne Taylor for any complaints.

Official Registry Statement

Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website:

Instructional Delivery Method

Group Internet Based

Course Registration Requirements

Online Registration

Refund/Cancellation Policy

Please contact the ACPEN help desk 1-877-602-9877 or if you wish to cancel your attendance for a previously purchased webcast and are requesting a refund or transfer. 



Overall:      4.4

Total Reviews: 17

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