The Internal Revenue Code, along with the related Treasury Regulations and other IRS guidance material, contains innumerable procedures that tax return preparers (and taxpayers) must follow.  Navigating these myriad and complex procedures can be difficult, and our firm has extensive experience in guiding tax preparers through the IRS's procedural labyrinth.  We routinely advise and work with tax return preparers on:

  • IRS Examination & Appeal: We represent clients at all stages of the IRS examination process - from negotiating the scope of an audit, to formulating responses to Information Document Requests, to preparing pre-filing agreements and private letter rulings.  If necessary, we can represent you or your company in the administrative appeal process, which can include fast-track settlement, mediation, or arbitration.

  • IRS Penalty Assessments & Abatements: The Internal Revenue Code contains scores of penalty provisions.  The failure to file a timely federal income tax return or a federal information return can result in significant penalty assessments.  We have extensive experience in working with the IRS and the IRS Appeals unit in having these penalties abated.

  • IRS Collection Matters: The IRS Collections unit is charged with collecting outstanding tax debts from businesses and individuals.  We have deep experience in working with the IRS to address collection issues through administrative procedures, including the representation of clients in collection due process hearings.  In addition, we routinely negotiate installment agreements and offers-in-compromise in order to resolve our clients' outstanding tax debt issues.

The firm's practice is primarily focused on assisting clients of all sizes in resolving their tax disputes with the IRS in a cost-effective manner.


  • Remedying missed or late filed regulatory elections (e.g., missed check-the-box elections and missed dual consolidated loss filings)
  • Closing agreements and pre-filing agreements with the IRS
  • Securing private letter ruling requests from the IRS national office
  • Relevant IRS programs and initiatives, such as the Offshore Voluntary Disclosure Program
  • Issues related to unfiled or late-filed international information returns
  • Dealing with errors on previously-filed income tax returns
  • Refund issues, including statute of limitations issues
  • Reportable transaction and material advisor issues
  • Issues related to on-going IRS examinations, such as preparing responses to IDRs and advising on relevant examination procedures, such as the technical advice memorandum procedure
  • The applicability of the rules of professional conduct to tax return preparers