THE 2026 PASS INCLUDES THIS COURSE. 


Do NOT purchase this course separately if you buy a 2026 PASS.


Non-filers present unique challenges for tax professionals, ranging from multiple years of unfiled returns to potential IRS enforcement actions. This course provides a practical framework for addressing non-filer cases, from gathering information and determining income to prioritizing filing years and communicating with the IRS. Participants will also learn how to manage client expectations and transition non-filers into long-term compliant clients.


Learning Objectives:

  • Identify common issues and risks associated with the non-filer cases.

  • Explain methods for determining income and expenses.

  • Explain how to determine which tax returns must be filed.

  • Describe the IRS substitute for return (SFR) process and how to submit a reconsideration of an existing SFR assessment.


Education Information:


IRS Program Number: NMVBP-T-00327-26-O

Credit Hours: 2 CPE (NASBA); 2 CE (IRS)

Prerequisite: None

Advanced Preparation: None

Program Level: Basic

Delivery Method: Group Internet Based (NASBA); Online Webinar (IRS)

Field of Study: Taxes (NASBA); Federal Tax Topics/Federal Tax Related Matters (IRS)


Instructor: Thomas Gorczynski, EA, CTP, USTCP Learn more about our instructors here.

If you can't attend this live webinar, you'll be automatically enrolled in the on demand version of this course where you can still earn CPE/CE. 

Refund Policy: Refunds processed prior to noon ET the day before the live event are subject to a $25 processing fee. No refunds will be given for live webinars after noon ET the day before the event, but if you are unable to attend the live webinar for any reason you will be given access to the on demand webinar on the same topic.  Click here for more information about our education, refund, and complaint policies. 

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