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Tax Controversy Matters (MP3)


Self-study hours are logged by the listener and the one page list is kept in an MCLE compliance folder. The log requires a listing of each program title, the program's approved MCLE provider name, program length, and whether or not that program contains mandatory subfield credit (legal ethics, elimination of bias, or prevention of substance abuse.)

Participatory hours require a proctor (any adult who is not simultaneously using the same program for participatory credit) to complete and sign documents accompanying each participatory program. Those completed and signed documents are subsequently returned to Versatape and individual certificates of compliance are prepared and returned to the listener to be filed in a MCLE compliance folder. Versatape will also keep a copy of the certificates of compliance on file. If audited the State Bar will be looking for a copy of those completed certificates of compliance and a copy of the self -study hours log.

Note: Please note MCLE audio program hours listened to in excess of 25 hours in a 3-year compliance period cannot be carried over into the next 3-year cycle.

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Just click and add the select audio package to your cart and we will assemble it for you based on best selling and recent programs.

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Choose your categories of interest and we will select available programs from the areas you choose. Additionally, you can add specific programs SKU's numbers which will be included in your package in addition to your preferred categories.

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Assemble your own 12 hour, 13 hour. or 25 hour package. Simply copy and paste the SKU number of each program you would like included into the Specific Programs Desired section and we will build your custom package for you. Remember to include the required subfield hours (if you need them): 4 hours of legal ethics, 1 hour of the elimination of bias and 1 hour of the prevention of substance abuse programs to your list (we can select them for you if you desire).

How They Work

MCLE Credit: 1 hour 

This seminar was recorded January 21, 2020 and updates us on federal and state tax controversy matters 

  • Avoiding Preparer Penalties and OPR Discipline
  • The Preparer Penalty Statute
  • Corresponding CIR. 230 Provisions
  • General and Specific Due Diligence
  • Preparer Penalty Procedural Issues


  • The Regulatory Framework
  • The 6694(a) Penalty
  • Types of Authority
  • Case Law in Taxpayer’s Jurisdiction
  • Understatement due to willful or reckless conduct


  • The 6694(b) Penalty
  • What does willful mean?
  • How to the regulations define willful?
  • What does reckless mean
  • What does intentional mean?
  • Avoiding the reckless or intentional characterization (§1.6694-3©(2))


  • The Circular 230 Corollary
  • §10.34 Standards w/r/t tax returns…
  • Meaning of the term preparer
  • Identity of prepare determines liability for penalty (§1.6694-1(b))
  • Due Diligence Requirements
  • Due diligence regulations (§1.6694-1(e))
  • §10.22 Diligence as to accuracy
  • The Understatement
  •  Procedural Consideration

Program materials included. Speaker: Chad Nardiello, Esq.. Recorded January 21, 2020. MCLE Credit: 1 hour


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Programs by MCLE Approved Providers:

San Fernando Valley Bar Association (#451)

Pasadena Bar Association (#531)

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