If you would like to confront the IRS in court and get a clear “yes” or a clear “no”, we can help you find a good tax law firm. With that referral and one million dollars for fees, you should be able to get the answer from the court within the next five years.
If, on the other hand, you would like to come to an early understanding with the IRS, we specialize in getting good answers quickly.
We have been representing taxpayers for 13 years at the IRS. We believe that strategy used to reach agreement is as important as the money in the deal or whichever party has the most court citations.
We were successful in reducing an examination to 30 days. The client received the standard examination opening letter. Instead of assuming that a normal three- to four-year examination would ensue, we met with the agent and IRS management. We agreed that questionable items on the returns were very explainable and IRS surveyed the returns.
A large real estate investment partnership examination was scheduled. We prepared the client to be examined, and met with the examiner and IRS management. The entire process lasted 44 days and the returns were “no changed.”
A large high-tech company was faced with a 24-month examination. We met with the Exam team and IRS management. With good examination and planning, the entire exam was concluded in seven months.
A large high-tech company discovered a potential problem in the issued stock options. We took the question to IRS as a potential Directors Determination. The potential exposure was more than $50,000,000. The Director’s Determination resulted in no tax due.
When you get the appointment letter to start an examination, we assist by meeting with the IRS to talk them through the return. If we can explain the items on the return adequately, the return can be “surveyed” which means no further examination. Time savings–Huge.
Penalties are negotiable. Not always for pennies on the dollar as advertised by some fly-by-night firms, but reasonable settlements can be negotiated.
Most settlements are not achieved by hard bargaining. You cannot hard bargain with the government. The IRS has unlimited time and no fear of losing. The best settlements are achieved by crafting a solution which will not break the bank at the client company, which the IRS can accept. It must be reasonable and supportable.
The traditional route of disagreements with IRS was Exam to Appeals to Tax Court. One, two, three, and out! A new intermediate step has been inserted at the close of Examination consideration. It’s called Fast Track Settlement! Both parties (IRS Exam and the company) may request the assistance of an Appeals Officer to help mediate the disagreement. If successful, the issues are often settled in one day; if unsuccessful, the matter goes the normal route to Appeals. The new Appeals Officer is only informed that Fast Track was attempted, but was unsuccessful.
Tax liabilities can be compromised. Offers in compromise are a specialty of the firm. When they can’t be compromised, many forms and schedules of payment can be arranged.
Appeals Officers are trained and instructed to entertain reasonable settlement proposals. They are not in the business of providing miracle solutions for your approval. We must craft the settlement, it must be fair to you and the government, and we must sell the government on the fact that it is fair! If there is an extremely creative way to end the dispute, you and I are responsible for crafting the solution.