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 collection, examination, and administrative appeals processes.

CATEGORIES of EXAMINATIONS and REPRESENTATION:

• EXAMINATION SELECTION PROCESS: Returns are chosen for audit based on a sophisticated scoring system, with higher scores indicating a higher likelihood of adjustments. Understanding common triggers, such as round numbers, unusual business expenses, or omission of income that is known to the IRS is crucial in return preparation to minimize the probability of return selection for audit.
• TYPES of AUDITS: Audits vary in complexity. Service Center Examinations are generally limited to simpler returns and seek verification of a few items. Office Examinations target more complex 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 audits. 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.
• FILING APPEALS: Taxpayers can appeal 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).