941 Collections Representation Quick Start & Toolkit

In May 2019, a group of 65 dedicated taxpayer representatives assembled together in Phoenix, AZ to acquire new skills that would enable them to represent small businesses with payroll tax debts.

Why work 941 cases?

Really, it boils down to three reasons:

  1. Payroll tax debtors make up 59% of all IRS Collections cases in inventory.
  2. Small business cases are more varied, fun, and interesting to work on.
  3. These clients have much more to lose from enforced collections action, and therefore are more motivated to resolve the problem.
  4. Business clients generally have better cash flow, making it easier for you to get paid.
  5. Payroll tax cases command significantly higher fees than 1040 representation.

In this three-day immersion program, attendees took a “deep dive” into the core principles of resolving IRS payroll tax liabilities for small businesses. Utilizing a case study approach, they learned how to evaluate a business for IRS program eligibility, how to negotiate the best resolution option for their business clients, and how to address the Trust Fund Recovery Penalty.

Not only that, but attendees learned specific marketing strategies to help them attract these lucrative cases.

Now, you have the opportunity to follow in their footsteps, and join the legion of tax professionals that are helping save jobs and family businesses across the country.

Note: This was a live CPE event. However, the recordings are not eligible for continuing education credit.


May 6
0800-0940: Intro to 941 Resolution (Dan Henn)
1000-1140: Business Financial Analysis (Jassen Bowman)
1145-1300: Lunch Provided
1300-1440: In-Business Trust Fund Installment Agreements, Business CNC, Biz OIC (Dan & Jassen)
1500-1550: Bits ‘n’ Pieces: Tips from the Trenches with Renee Sieradski, EA
1550-1640: Case Study Exercise Discussion + Q&A Time

May 7
0800-0940: Trust Fund Recovery Penalty Representation (Jassen Bowman)
1000-1140: Worker Classification Cases (SS-8) (Dan Henn)
1145-1300: Lunch Provided
1300-1440: The “New Company Flip” Strategy (Jassen Bowman)
1500-1550: Employee Shared Responsibility Payment (ESRP) Representation of Applicable Large Employers (Dan Henn & Cathy Strobeck)
1550-1640: Case Study Exercise Discussion + Q&A Time

May 8
0800-0940: Building a Wealth-Focused Boutique Tax Practice (Jassen Bowman)
1000-1140: B2B Tax Resolution Marketing Demo (Jassen Bowman)
1145-1300: Lunch Provided
1300-1530: Building Personal Wealth Via Real Estate & Growing the Real Estate-Focused Side of Your Practice (James Orr & Jassen Bowman)
1545-1635: Q&A + Wrap-Up

Detailed Session Information

Introduction to Resolving 941 Tax Debts

This session will introduce the practitioner to the resolution of employment tax debts. Attendees will learn about how to avoid these tax debts in the first place, the 941-specific penalties, and the application of SB/SE enforcement priorities. We’ll also look at 941-specific resolution options.

Session Objectives

  • Define the penalties related to employment tax debts.
  • Articulate the resolution pathways available to 941 debtors.
  • Understand the application of SB/SE enforcement priorities.

Small Business Financial Analysis & Form 433-B

This session will cover the Collection Information Statement for Businesses and how the IRS conducts financial analysis on businesses to reach a collection decision.

Session Objectives

  • Understand the purpose of IRS Form 433-B.
  • Apply IRS Financial Analysis Handbook procedures to business revenue and assets.

In Business Trust Fund Installment Agreements & Business CNC

Contrary to popular belief, about 75% of all tax debtors will wind up on some sort of payment plan to the IRS.

Session Objectives

  • Understand the pros and cons of an installment agreement.
  • Define the various types of installment agreements and their qualifications.
  • Understand the installment agreement process.
  • Define the requirements for pending IA status.
  • Define the requirements and processes for entering CNC

Trust Fund Recovery Penalty Assessment: Who’s on the Hook?

When a business owes unpaid payroll taxes to the IRS, they will soon start looking for an individual to blame. If the IRS can demonstrate that any individual was responsible for paying certain taxes, and willfully failed to do so, they can be held personally liable for the trust fund portion of the liability. This session will provide an overview of assessment critieria, walk you through the determination process, and show you how to defend your clients against personal assessment.

Session Objectives

  • Define Trust Fund Recovery Penalty assessment criteria.
  • Explain the conditions necessary for an individual to be declared a responsible party.
  • Explain the conditions necessary for an individual to be declared a willful party.
  • Review the completion of IRS Form 4180.
  • Discuss defenses against personal assessment.

Worker Classification Cases (SS-8)

When an employer misclassifies employees as independent contractors, either intentionally or not, the employer becomes responsible for back-payment of payroll taxes. This session will cover the nuances of these unique cases, including the special types of relief available to small business owners.

The “New Company Flip” Strategy

This class will cover a unique strategy that allows a business to be reconstituted under new ownership while continuing to service it’s existing customers, a procedure that, when done properly, allows a business to have a fresh start — wiping away non-Trust Fund liabilities — and also avoid alter ego/nominee assessments.

ESRP Representation

Starting in February 2018, the IRS initiated a brand new enforcement program: Chasing down Applicable Large Employers (ALEs) for the Employee Shared Responsibility Payment for failing to provide health insurance to workers as required under the Affordable Care Act. This new tax has an alarmingly high “miss” rate — meaning the IRS is sending bills to companies that are actually not big enough to have an ESRP requirement. This course will cover defense of these unique and growing case situations, both for that legitimately owing the tax and for those that are being erroneously caught up in the enforcement sweep.

More session descriptions coming soon.

About the Instructors

Jassen Bowman, EA spent eight years exclusively representing tax debtors as an Enrolled Agent. He has presented over 300 live seminars and webinars to CPAs, EAs, and attorneys on the subjects of IRS Collections representation, practice management, and growing a tax firm. He is the author of several books, including Tax Resolution Secrets for consumers and Tax Resolution Systems, a checklist manual for practitioners.

Dan Henn, CPA is an entrepreneur, tax education speaker, author of the “No Holds Barred, Candid Talk About Small Business Success In Florida”, and tax columnist with Florida Today. With over two decades’ worth of expertise, he currently dedicates his time to assisting business owners in saving on taxes and growing their businesses primarily in the areas of real estate taxes and IRS Collection cases.


To enroll in this unique program for a one-time payment of only $1995, click here to checkout.