Tax Controversy Representation

Each year, 20 million taxpayers have an issue with the IRS.  Jim has extensive experience in resolving tax disputes, both with the IRS and State Departments of Revenue.

Jim offers the following tax controversy representation services in these areas:

  • Audits
    • Mail audit responses and representation, reconsiderations, and appeals
    • Office and field audit representation, reconsiderations, and appeals
    • Offer in compromise- doubt as to liability evaluation and representation
  • Employment tax issues
    • Trust fund recovery penalty investigations
    • IRS Voluntary worker reclassification programs
    • Employment tax audits
    • Worker reclassification determinations
  • Collection issues
    • Collection alternative consultations
    • Representation for extensions to pay, installment agreements, and currently not collectible status
    • Offer in compromise (both doubt as to collectibility and effective tax administration) evaluation and representation
  • Penalty relief
    • Pre-assessment audit relief options and representation
    • Penalty abatement evaluation and representation
  • Account Adjustments
    • Relief from joint/severable liability (innocent spouse)
    • Tax identity theft
    • IRS discrepancies
  • Underreporter Notices (Cp2000, CP2501, etc.)
    • IRS response, representation, reconsideration, and appeal
    • Penalty assessment and abatement evaluation and representation
    • Offer in compromise- doubt as to liability evaluation and representation
  • Sales and use tax audits
    • State representation
    • Risk analysis and evaluation consulting
  • Tax-exempt organization issues
    • Tax-exempt status reinstatement
    • Tax-exempt audit representation (including employment tax issues)
  • IRS large case examination representation/consultation
    • IRS Coordinated Examination Program best practices consultation
    • Representation as point-of-contact/coordination with the IRS
    • End-to-end management of Communications Agreement, Information Document Requests (Forms 4564), Proposed Issues (Forms 5701), dispute resolution, and appeals

Contact us today to get started.