Free CLE, and Cal. CPA CE, from a dual-certified legal specialist.

Specialist CLE is a free MCLE site I maintain as a dual-certified specialist in Taxation Law and Appellate Law. I post short updates on California tax controversy and appellate practice as the law develops — each one a two-part video worth half an hour of self-study credit for California attorneys, with CPA CE on the tax activities. Watch, register, download your certificate.

— Thomas Ogden

State Bar of California MCLE provider no. 19437 (Law Offices of Thomas Ogden). Attorneys licensed elsewhere are welcome and should confirm credit with their own bar.

Thomas Ogden

Appellate Law

Case law updates

1

California Appellate Update — September 2026

Three Court of Appeal opinions and one Supreme Court grant from this month that affect preservation and appealability.

[Case] (2026) __ Cal.App.5th __ · [Case] (2026) __ Cal.App.5th __ · [Case], S______ (review granted Sept. 2026)

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Fundamentals

3

Standards of Review in 30 Minutes

Why the standard of review usually decides the appeal, and how to frame an argument around it.

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Preserving the Record in 30 Minutes

What has to happen at trial for an issue to survive on appeal, and the objections most often lost by omission rather than by ruling.

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Tax Law

Case law updates

1

Tax Controversy Update — September 2026

Three decisions from this month that change how audits and Tax Court petitions should be handled.

[Case] v. Commissioner, T.C. Memo. 2026-__ · [Case] v. Commissioner, 167 T.C. No. __ · United States v. [Name] (9th Cir. 2026)

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Fundamentals

3

IRS Audits in 30 Minutes

The audit process from initial contact through Appeals, and where a practitioner's involvement changes the outcome.

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Tax Court Petitions in 30 Minutes

Filing a petition, the stipulation process, and what distinguishes Tax Court practice from other federal litigation.

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Who can claim credit

California attorneys

Each activity is a 30-minute self-study MCLE activity from a State Bar approved provider, worth 0.5 hour. Watch both parts, register, download your certificate. Self-study counts toward the 12.5-hour self-study portion of your 25-hour requirement.

California CPAs

Tax activities follow the Board of Accountancy self-study format. After watching, you answer six review questions on the activity page (each with feedback), then pass a five-question multiple-choice exam to receive your certificate. Each activity is 0.5 hour of CE in the Taxes subject area. The videos are the same for everyone.

Attorneys licensed in other states

You're welcome to take any activity. These are California State Bar approved self-study activities; whether your state accepts them depends on its own rules, so check with your bar before claiming the hours.