Seeing a rise in S corp K-1 suppression and circular management fee flows; I’m looking for CPE that goes deep on reconstructing income (bank deposits/net worth) and evidentiary thresholds for 26 U.S.C. §7201 versus §7206(1). If you’ve taken a 2025 course or workshop that covered ERC and pass-through abuse with practical workpapers in IDEA or Alteryx and clear treatment of civil fraud (§6663, 75%) versus criminal exposure, which providers felt most actionable?
On “circular management fee flows,” I’ve caught S corp K‑1 suppression by joining vendor/payee names to EINs and running a quick cycle-detect in Alteryx to flag 3+ hop loops, then reconciling with a bank‑deposits tie‑out. For 7201 vs 7206(1), keep DOJ’s CTM and IRM 4.10.4 handy — the proof elements and indirect method steps are laid out cleanly: https://www.justice.gov/tax/criminal-tax-manual and https://www.irs.gov/irm/part4/irm_04-010–004. @OP most 2025 CPE skim ERC workpapers; you’ll get more mileage from tool labs plus your own templates.
@OP ‘bank deposits’ is great, but tag ERC inflows separately (watch for IRS TREAS 310 and 941‑X descriptors) so you don’t overstate receipts; in Alteryx I regex ACH/wire memos to flag management fee flows and then pivot by EIN to surface K‑1 suppression against distributions. Minor caveat: if you only have PDFs, push the bank for native CSV or those memo strings disappear.
Won a July 2024 denial with a Higher‑Level Review by checking the informal conference box on VA Form 20‑0996 — no new evidence, just correcting a duty‑to‑assist miss.
I’ve quantified it with a 6‑week diff‑in‑diff: segment JP/KR traffic, hide “13” and 4xx on treatment while holding price constant (“ADR stayed flat”), and track upgrade attach + cancels vs. control floors; we saw +0.7% RevPAR net after fees and a small upsell bump. Novelty decays fast — — so re‑labeling helps only if the booking path surfaces the “lucky” choice; otherwise the lift fades by week 8. @mia_huang77 did you see the gain concentrated where guests could pick floors in‑path, and in your 312‑key case was that 0.6% mostly mobile?