IRS & State Representation

When dealing with IRS, FTB, or other State Tax Agency audits, collections, or appeals, be cautious in communicating yourself with agency employees to avoid potential financial consequences. Representing yourself or relying on inexperienced individuals may result in an unexpected and potentially significant tax liability far exceeding the cost of professional representation.

Leveraging my extensive IRS employee technical and managerial experience as a Revenue Officer, Internal Revenue Agent, Field Examination Manager, and Associate Chief in Appeals, I specialize in guiding clients through the tax collection, examination, and administrative appeals processes.

CATEGORIES of EXAMINATIONS and REPRESENTATION:

• EXAMINATION SELECTION PROCESS: Returns are chosen for potential tax audit based on a sophisticated scoring system, with higher scores indicating a higher likelihood of adjustments. Understanding common red flags, such as many round numbers (indicating likely estimates), unusual business expenses, or omission of income that is known to the IRS is crucial in return preparation to minimize the probability of tax return’s selection for audit. Beside the scoring system, returns can be selected for audit based on other criteria. One of the most common is the related pick-up (for example, a corporation is under audit, and the Revenue Agent decides to examine the officer or shareholder’s return).
• TYPES of AUDITS: Audits vary in complexity. Service Center Examinations (the most common) are generally limited to simpler returns and seek verification of a few items. Office Examinations target more complex tax returns and are assigned to a Tax Compliance Officer who will schedule an in-person appointment at a local IRS office. Field examinations are the most serious and time-consuming tax audits. These audits generally involve businesses, estates and trusts. These are conducted by experienced Internal Revenue Agents.
• REPRESENTATION PROCESS: In representing clients undergoing an audit, it is crucial to be aware of IRS policies, procedures, the Internal Revenue Manual, pertinent court cases, and other authoritative sources to ensure a just resolution to the examination or audit. Effective communication with IRS personnel is key to navigating audits successfully. Knowing what to say and what not to say can make the difference between a simple low- or no-cost resolution or a significant deficiency (tax due) with possible penalties due to extensive changes to the return. Understanding taxpayer rights and the administrative appeals process is essential for achieving favorable outcomes.
• COLLECTION REPRESENTATION: With insights from my tenure as an IRS Revenue Officer and my 19 years in IRS Appeals, I provide strategic guidance in addressing IRS collection procedures, including interactions with Service Center Collection, the Automated Collection System (ACS), and Revenue Officers. Some of the actions I take include levy and lien releases, setting up installment agreements, negotiating an offer in compromise, obtaining innocent spouse relief, and other resolutions.
• FILING APPEALS: Taxpayers can appeal IRS audit determinations as well as IRS enforcement actions such as tax liens, levies, or seizures. Timely, well-reasoned, and supported appeals are critical, with options including IRS Collection Due Process (CDP) hearings and the IRS Collection Appeals Program (CAP).