Help Your Clients Avoid Potential Penalties
Related to Section 199A This Tax Season!

The Section 199A statute and regulations have left many CPAs and other tax professionals with many common questions unanswered.  Well into the tax season, it is imperative that practitioners evaluate what position to take and whether there is sufficient authority. Part of this analysis is determining what, if any, penalties might apply should the IRS audit.

In particular, estate planning professionals also need to be aware of the impact of the Section 6662(b)(2) substantial-understatement penalty. For taxpayers that decide to take a Section 199A deduction, there’s a special rule that decreases the threshold which triggers this penalty.  With a basic understanding of how to disclose positions and demonstrate sufficient authority for the position, the this penalty can be avoided.

That is why you will want to join us and nationally renowned CPA and tax expert, Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA, in one of Bob’s most timely, insightful and actionable presentations yet entitled, “Penalty Proofing 199A Issues When Filing Income Tax Returns”.   Joining Bob will be nationally recognized tax lawyer, Michael G. Goller, J.D.  Michael brings an unmatched level of understanding and expertise of the law with a practical approach on how to help better protect your clients.

During this 60-minute presentation, Bob and Michael will address the following:

  • Framing out the critical potential penalties with Section 199A issues
  • Reviewing the trade or business issue and the multi-entity issue
  • Addressing aggregation elections and penalties and Notice 2019-7 Elections
  • The separate and separable issue
  • The statutory employee issue
  • A look at the multiple trust rules and the impact of these particular provisions
  • A review of the potential penalties under the Internal Revenue Code
  • Understanding the levels of assurance for penalty waivers
  • Utilizing opinion letters to reduce a client’s potential exposure
  • How and when to use Form 8275 disclosures
  • And much more!

Your purchase includes: Downloadable PDF handout materials and an MP3 audio recording for just $99. A PDF transcript to your purchase during the checkout process for an additional fee.

Michael G. Goller

Michael G. Goller

Michael G. Goller is a shareholder and chair of Reinhart’s Tax Practice. He is a member of the firm’s Litigation and Corporate Law Practices. His practice focuses on tax controversy, tax litigation, and tax planning. The clients Michael represents include large, public corporations, mid-sized, privately held businesses and their owners. He handles a wide variety of tax-related issues, including complex income and estate and gift tax controversies. Michael represents clients involved in disputes with the IRS, the Department of Justice, and various other taxing authorities before the United States Tax Court, various Federal district courts, the United States Court of Federal Claims, various state courts and the Seventh Circuit Court of Appeals.

As an experienced tax attorney and tax litigator, Michael assists his clients in navigating the challenges associated with complex federal and state tax audits, disputes, administrative appeals, trials and subsequent appeals. Michael serves as a trusted advisor and legal strategist who is able to draw upon his vast knowledge and experience to offers unparalleled proficiency in his field, which is evidenced in his impressive track record of successfully trying cases to favorable settlements. Clients appreciate that Michael has the personality of litigator with the expertise of a tax attorney and provides legal advice from this unique intersection.

Robert S. Keebler

CPA/PFS, MST, AEP (Distinguished), CGMA
Robert S. Keebler

Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planning Counsels. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. Mr. Keebler is the past Editor-in-Chief of CCH’s magazine, Journal of Retirement Planning, and a member of CCH’s Financial and Estate Planning Advisory Board. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. Mr. Keebler frequently represents clients before the National Office of the Internal Revenue Service (IRS) in the private letter ruling process and in estate, gift and income tax examinations and appeals.

In the past 20 years, he has received over 150 favorable private letter rulings including several key rulings of “first impression.” Mr. Keebler is nationally recognized as an expert in estate and retirement planning and works collaboratively with other experts on academic reviews and papers, and client matters. Mr. Keebler is the author of over 75 articles and columns and editor, author, or co-author of many books and treatises on wealth transfer and taxation, including the Warren, Gorham & Lamont of RIA treatise Esperti, Peterson and Keebler/Irrevocable Trusts: Analysis with Forms.

Mr. Keebler is a member of the editorial board of the Society of Financial Service Professionals “Keeping Current” series. He is a featured columnist for CCH’s Taxes Magazine – “Family Tax Planning Forum,” Steve Leimberg’s “News of the Week Newsletter” and the Bureau of National Affairs Tax Division. Bob also had his article “Is That Your ‘Final’ Answer?” published in Tax Management Compensation Planning Journal. Bob frequently is quoted in national publications such as New York Times, Chicago Tribune, Baltimore Sun, Barrons, Bloomberg Wealth Manager, Financial Advisor, Forbes, Kiplinger, Lawyer’s Weekly, On Wall Street, The Wall Street Journal, USA Today, Wealth Manager and Worth in addition to many local and regional newspapers.

He is a frequent speaker for legal, accounting, insurance and financial planning groups throughout the United States at seminars and conferences on advanced IRA distribution strategies, estate planning and trust administration topics including the AICPA’s Advanced Estate Planning, Personal Financial Planning Conference and Tax Strategies for the High Income Individual Conference.

Mr. Keebler graduated (cum laude) from Lakeland College with a degree in Accountancy and the University of Wisconsin – Milwaukee with a Masters in Taxation. Before practicing in Northeastern Wisconsin, he practiced with Price Waterhouse where he concentrated in taxation.


The Ultimate Estate Planner, Inc. and the presenter are not registered Continuing Education Sponsors and this program is not pre-approved for continuing education credit for any state or regulatory agency.

However, please note that each program includes a Certificate of Completion and, depending on the license and the regulatory agency for which governs a participant’s CE credit, some professionals may be able to self-report his or her participation and receive credit. It is the responsibility of the participant to complete any process necessary to seek self-reported CE credit for his or her participation. By registering for a teleconference (or purchasing on On-Demand program), you understand that CE credit is not guaranteed or warranted by the presenter or The Ultimate Estate Planner, Inc.

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