IRS Audit Defense, Appeals Representation, and Penalty Abatement Requests

IRS AUDITS HAPPEN. ARE YOU READY?

The IRS and other tax authorities are getting more aggressive and sophisticated every day. When the IRS knocks on your door, it’s typically an unexpected event, and it can happen at the worst possible time. Many businesses and individuals find themselves under audit or dealing with back taxes and penalties for a multitude of reasons. Some may be valid; some may be not. If you are under IRS audit, we can help, but our assistance starts way before our clients are audited by the tax authorities. We like to be pro-active and develop tax filing positions for our clients prior to filing their tax returns. This approach allows us to face any challenges by tax authorities well prepared, and our clients understand any potential tax exposure. We have been working diligently to sharpen our experience and improve our methodologies in delivering top notch maximum efficiency tax resolution services with a personal touch. Note that sometimes a resolution may not be as favorable to taxpayers as one would like it to be; but we will work hard in protecting your interests before the IRS to achieve most optimal outcomes.

Our tax advisors will help you deal with the IRS and other government agencies confidently and with ease. Our team specializes in effective and result-oriented solutions and representation for taxpayers who are going through an IRS audit, have unpaid taxes, delinquent tax returns, or are facing penalties and interest. 

 Our approach and services

We will work with you to analyze the specific facts and circumstances of your situation. It is important that during this process we have complete transparency and full disclosure of any prior correspondence or dealings with the IRS or other tax authorities. We will research the tax law and precedents relevant to your case, analyze your situation, develop arguments to protect your interests, document our position, and share our findings with you. We will carefully explain all available options and procedural alternatives, get your thoughts and come up with a recommendation on the best proposed course of action. We will then proceed to get it done. More importantly, get it done right.

Problems are there to solve and we love solving tax problems for our clients. We will passionately pursue your interests and get you the best possible outcome (subject to your facts and circumstances and the applicable tax authorities)!

Our tax controversy services include, but are not limited to:

• Settlements of back taxes with less than what you owe based on an offer in compromise;
• Negotiating and setting up a payment plan on your terms within framework established by the applicable tax authorities (such as negotiating installment agreements with the IRS);
• Under applicable facts, reducing or eliminating penalties via penalty abatement and waiver requests;
• Putting an end to wage garnishments, bank levies and/or tax liens;
• Requesting innocent spouse relief;
• Preparing delinquent (unfiled) tax returns, getting you compliant with foreign bank account reporting (FBAR) and international information reporting requirements;
• All aspects of IRS audit defense, support in an ongoing examination, and representation in Appeals;
• Managing transfer pricing audit;
• Requesting competent authority assistance to eliminate or reduce double taxation;
• Resolving state and local tax issues.

Our team will work hard and smart to get you the most optimal results!

Tax resolution is a personal matter that involves a lot of unique considerations and is something you want to entrust to the people who know it best. The procedural requirements, including applicable statutes of limitations need to be carefully examined to determine what tax dispute resolution options may be available to you or your business.

For instance, pursuant to the U.S. tax law, the accuracy related penalties should not be assessed when the taxpayer acted with reasonable cause and did not have a willful neglect. The determination of whether a taxpayer can use reasonable cause defense depends on all facts and circumstances, and the IRS considers the education and background of the taxpayer to determine if reliance on a qualified tax professional, for example, may qualify for reasonable cause relief. 

Tax regulations have varying and sometimes blurry definitions for critical terms like “reasonable cause,” “willful conduct”, “good faith,” “willful neglect” and other applicable terms, which may provide ample or some room for interpretation and argument. This shows you how subjective and almost psychological things can get in the way of tax resolution. We’ve been through this many times and will guide you through this maze!