Taxpayer Representation


A key element of a Specialty Tax Firm is being able to defend items on the tax returns or elements of tax planning when challenged by the IRS. Representing Taxpayers requires being licensed as an Enrolled Agent, Attorney, or CPA. Enrolled Agents are licensed by the US Treasury to represent taxpayers in all 50 states. Attorneys and CPA are generally limited to practicing in the state that issued their license.

Representing Taxpayers requires knowledge of the law and IRS practice and procedure. Knowledge of the law helps protect the taxpayer’s rights, understand the requirements for proper treatment of a tax item, and how to defend taxpayer positions. Knowledge of IRS practice and procedure helps identify and predict inquiry, requirements, and responses of IRS employees. These are the rules the IRS is required to follow. When properly understood, these rules may be used to control almost any situation.

Tax law and authority include the Internal Revenue Code, Treasury Regulations, Revenue Rulings, Treasury Decisions, US Tax Court Cases, and higher court decisions. We also use other sources of lesser authority to help us understand IRS positions under certain facts and circumstances.

IRS practice and procedure involves understanding the “IRS Playbook” – The Internal Revenue Manual. The IRS also has a variety of “Policies” that define their mission, values, priorities, and deference that can often be used as a means to strengthen the taxpayer position.



  • We answer Correspondence from the IRS and State Tax Authorities.
  • We Represent Taxpayers in Examinations and Audits before the IRS and State Tax Authorities.
  • We Research and Prepare Unfiled Returns
  • We Challenge Substitute for Return and other Assessments through Audit Reconsideration 
  • We Protect the Taxpayers Rights and Due Process 


  • We Stop Wage Garnishments, Liens, and Levies
  • We Negotiate Payment Alternatives to Stop Forced Collection
    • Have the taxpayer placed in Currently Not Collectible Status (CNC)
    • Negotiate an Installment Payment Agreement (IPA) to repay the tax debt in full, or partially.
    • Negotiate an Offer in Compromise to settle the tax debt for less than the full amount.


  • We Appeal Unfavorable IRS Decisions
    • Examination Appeals
    • Collection Due Process (CDP)
    • Collection Appeals Program (CAP)
  • We Abate Penalties whenever possible