The IRS sends out 100 million notices every year, and up to 50% of them are wrong. In this session from Provision Conference 2026, 45-year tax litigation specialist Dan Pilla walks small business owners through exactly what to do when a notice arrives and how to challenge penalties. Two-thirds of all IRS enforcement actions are directed at small businesses and the self-employed. Dan Pilla, who has spent 45 years fighting the IRS, covers what small business owners are up against and how to legally fight back.