REPRESENTATION BEFORE IRS
Our firm provides unique capabilities in representation of clients before IRS because of the fact we have licensed professionals who are former IRS employees from the Criminal Investigation, Examination, and Collection Divisions.
Referred to as a “full service” tax firm, our abilities and experience enable us to provide clients with a myriad of services beginning with the initial preparation of books, records, and tax returns and continuing through the various civil and/or criminal processes that may arise during the statutory life of the tax return.
Employees within the firm have a combined approximate total in excess of 116 years experience dealing with IRS collection matters, not only from within the IRS, but on behalf of the public.
Over the years, the firm has represented thousands of clients on a national scale involving areas related to federal tax liens, levies and seizures, avoiding and minimizing the effect of tax liens and levies, discharges from federal tax liens, analysis of financial information statements, transferee assessments, bonds and collateral agreements, Offers in Compromise, trust fund recovery penalty investigations and defenses related to proposed assessments, tax, penalty and interest calculations, possible discharge of taxes through bankruptcy, summonses, summons enforcement and challenges related thereto, taxpayers’ rights and disclosure laws, installment agreements, jeopardy assessments, taxpayer remedies, statutes of limitation, requests for abatement, taxpayer assistance orders, claims for refund, IRS prepared returns under IRC 6020(b), innocent spouse provisions, IRS Automated Collection System, IRS Special Procedures, IRS Problem Resolutions, and IRS Service Centers.
The firm is actively involved in areas involving criminal tax controversies on a national scale. This representation often includes efforts necessary to avoid criminal investigations such as the preparation of voluntary disclosures, negotiations and/or strategies involving the civil examination process.
Once a criminal investigation has been established, our experience enables us to analyze the strengths and weaknesses of the government’s allegations, identify and interview relevant witnesses, conduct intense examination of the client’s books and records in a manner similar to that being conducted by the IRS, identification and accumulation of critical documents and other forms of evidence in defense of the client, and related Title 26 United States Code Sections.
The firm’s representation also includes negotiations to avoid prosecution with IRS special agents, district counsel, the Department of Justice in Washington, and the local U.S. Attorney’s Office.
Enrolled Agents (EAs) are federally-licensed tax practitioners who may represent taxpayers before the IRS when it comes to collections, audits and appeals. This profession dates back to 1884 when, after questionable claims had been presented for Civil War losses, Congress acted to regulate persons who represented citizens in their dealings with the U.S. Treasury Department. Enrolled agents’ expertise in the continually changing field of taxation enables them to effectively represent taxpayers at all administrative levels within the IRS.