Tax controversy · Circular 230 representation

An IRS letter is a deadline. We take it from here.

With a signed Form 2848, we become your point of contact with the IRS and state tax agencies. We answer the examiner, assemble the record and negotiate the outcome, so you are not across the table from an agent alone.

Speak with an advisor Call (703) 880-8412

Forms & standards

Form 2848Form 4564 IDRForm 4549Letter 525Form 656 OICForm 9465

The forms and rules that come up most often in this practice.

What we handle

Representation from the first notice to final resolution

Most audits are decided by the quality of the record and the discipline of the response. We control the scope of information requests, prepare documentation the examiner can follow, and keep the conversation on the issues the IRS actually raised.

When a case can't be resolved at examination, we prepare the protest and take it to the IRS Independent Office of Appeals. When the issue is a balance due, we negotiate a payment arrangement the business or household can actually keep.

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Correspondence, office and field examinationsIndividual, S corporation, partnership and C corporation returns.
Responding to Information Document RequestsWe scope and answer IDRs so you hand over what's required and nothing more.
Appeals and protestsWritten protests and conferences with the IRS Independent Office of Appeals.
Collections and payment plansInstallment agreements, offers in compromise and currently-not-collectible status.
Penalty abatementFirst-time abatement and reasonable-cause requests for failure-to-file, failure-to-pay and accuracy penalties.
Payroll tax and trust fund recoveryDefending owners and officers against Trust Fund Recovery Penalty assessments.
State and local tax auditsIncome, sales and use, and residency audits in DC, Maryland, New York, Virginia and other states.
Unfiled and amended returnsGetting back into compliance before the IRS reaches out first.

Where we help

Situations we're called in for

CP2000

Proposed changes to income

Matching notices where the IRS believes income was under-reported.

Field exam

An agent wants to visit

Business exams covering revenue, owner compensation, vehicles, travel and related-party activity.

Residency

A state says you never left

NY and other states auditing a move or a split-year return.

Balance due

Liens, levies and final notices

Stopping enforcement action and negotiating a resolution.

Our approach

How the engagement runs.

Review the notice

We read the notice, pull IRS transcripts and confirm the deadlines and what's at stake.

Take over contact

We file Form 2848 so the agent works through us, not you.

Build the record

We reconstruct support, write the explanations and answer each request in order.

Resolve

We close at exam, go to Appeals, or negotiate collection terms, and explain each option in plain terms.

Questions

Frequently asked

If your question isn't here, call (703) 880-8412 and you'll reach a person.

Do I have to meet with the IRS agent myself?

Usually not. Once a CPA is authorized on Form 2848, the IRS generally works through your representative. There are limited exceptions, such as when an agent needs to tour a business location.

How quickly should I respond to an IRS notice?

Check the response date on the notice. Many give 30 days, and some protest and Tax Court windows can't be extended. Contact us as soon as the letter arrives so the options stay open.

Can you help if I prepared the return myself or used another preparer?

Yes. A large share of our representation work involves returns prepared elsewhere. We review the original return as part of building the response.

What happens if we disagree with the auditor's findings?

You can ask for a manager conference and then file a protest with the IRS Independent Office of Appeals, which is separate from the examination function. We prepare and argue the protest.

Latest updates

IRS & federal tax

All IRS & federal tax updates

Oct 9, 2025IRS & federal tax

IRS releases 2026 inflation adjustments reflecting the 2025 tax law

New 2026 brackets, standard deduction amounts and other inflation-adjusted figures, including changes from the 2025 budget reconciliation law, apply to returns filed in 2027.

Source: Journal of Accountancy

Our guidance

Know your rights

Taxpayer rights in an IRS audit

The Taxpayer Bill of Rights, audit protections in the Code, and the path from audit letter to Tax Court.

Learn more Tax Court

Lessons from 2025–2026 Tax Court cases

What we learned from every opinion the court issued in 2025 and 2026.

Learn more Daily

New Tax Court case summaries

Plain-English summaries of each new opinion.

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U.S. Tax Court

Recent Tax Court opinions

All case summaries

Charitable donations · Valuation

Murphy Hollow, LLC and Hales Gap, LLC v. Commissioner

T.C. Memo. 2026-115Nov 5, 2026MemorandumChief Judge UrdaDocket 9620-21

Issue: Two LLCs bought adjacent Tennessee tracts for roughly $1,350 an acre and, a year later, donated them and claimed deductions of $26.7 million and $19.4 million.
Holding: Both deductions were denied in full because neither entity obtained a qualified appraisal; the managers knew the appraiser would overstate value. The 40% gross valuation misstatement penalty applies, plus the 20% penalty on the remainder for Murphy Hollow.
Why it matters: A deduction can be lost entirely, not just reduced, when the people running the deal knew the appraisal was inflated.

Filing status · Child credits

Butler v. Commissioner

T.C. Memo. 2026-116Nov 5, 2026MemorandumJudge MarshallDocket 6448-24

Issue: A father claimed head of household status, the child tax credit and the earned income tax credit for two sons who were also claimed by their mother.
Holding: The court sustained the IRS: he did not show the children lived with him for more than half the year, so he could not claim them or head of household status. The IRS conceded the accuracy-related penalty.
Why it matters: Separated parents claiming the same children need records of where the children slept, night by night.

Unreported income · Schedule C

Pinckney v. Commissioner

T.C. Memo. 2026-113Nov 4, 2026MemorandumJudge MorrisonDocket 5050-19

Issue: A tax-preparation business owner's 2008 and 2009 returns were examined; the civil exam was suspended during criminal proceedings and later resumed.
Holding: The court sustained nearly all adjustments, including gross receipts of about $377,000 and $341,000 versus roughly $200,000 and $143,000 reported, disallowed cost of goods sold, and treated the business as a disregarded entity subject to self-employment tax. His procedural objections were rejected.
Why it matters: Bank deposits drive gross receipts; a civil case can resume years later after a criminal case.

Insights

Often paired with this work.

Tax

Start a conversation

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Speak with an advisor (703) 880-8412