(This section for my clients contains copies of newsletters, highlights of tax law changes, and other items)
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Welcome to my website. As a United States Treasury licensed Enrolled Agent (EA) and Federally Authorized Tax Practitioner (FATP), it is my objective to provide you with valuable information about my background, qualifications and the types of tax resolution assistance and other tax services that I offer. I have included some important self-help links as well as technical discussions on a variety of topics.
At the outset, absolutely anyone facing a tax controversy can attempt to resolve their issues without professional help or guidance. In my 34+ years of IRS experience, I can say without hesitation that in my opinion, the vast majority of taxpayers - whether individuals, partnerships, corporations or other entity types - ended up with a better resolution or settlement when they were represented by professionals.
The IRS and State tax controversy resolution settlement process can be complicated. To be successful on their own, a taxpayer would have to devote a significant amount of time in studying the Internal Revenue Code, Regulations, case law, Rulings, Procedures. the Internal Revenue Manual (IRM - the "Bible" IRS employees must follow) and tax strategies for negotiating a favorable tax controversy resolution. Without this effort, I firmly believe that it is far more likely that a taxpayer will end up with a less favorable "deal" for himself or herself. Bottom line - the additional tax, penalty and interest the taxpayer will end up having to pay may be significantly more costly in the long run than the actual cost of representation by a tax resolution specialist that could have obtained a more favorable resolution.
In spite of what I hear from our leaders in Washington, it is my observation that our economy is in serious trouble, and you may have been adversely impacted financially in a way that simply makes tax audit or collection representation and resolution service costs unaffordable. While I generally do not recommend any taxpayer take on the IRS or State tax agency on their own, I am very sensitive to clients with financial challenges and may be able to suggest ways for them to get help and guidance while keeping their out-of-pocket costs down. For example, I have had a number of clients who were successful in getting their IRS and other state controversies resolved by having me "hold their hand" through the process using my help in a consultation capacity.
Here is an option to consider if your finances are tight. If you feel capable and comfortable of working over the telephone or face-to-face with an IRS Revenue Officer, IRS Revenue Agent, IRS Tax Compliance Officer (TCO), IRS Appeals Officer or IRS Settlement Officer, or any other employee involved in your IRS or California tax audit or collection controversy, then retaining me to hold your hand (which means that I will be providing you with an explanation of your options, strategic guidance, review of documents, and specific suggestions) could make the difference between the success or failure of your tax resolution efforts!
Let me stress this point again - generally, I do NOT recommend that anyone who does not have a good knowledge of IRS tax law and agency procedures attempt to resolve their own tax controversy themselves! Using the services of a tax resolution specialist - and particularly one with extensive and successful IRS technical employment experience - is advisable.
As a general rule, I do not recommend taxpayers use the services of their current accountant or tax preparer to represent them in an IRS or state tax audit or tax liability negotiations - unless they possess special skills and extensive experience in tax controversy resolution. In my decades of experience gleaned from my years of having been both inside and outside of the IRS, most accountants and preparers are very competent at return preparation, producing financial statements, and general accounting matters. However, sitting across the table from an IRS Revenue Agent, IRS Revenue Officer, IRS Appeals Officer or IRS Appeals Settlement Officer or an IRS Tax Compliance Officer demands specialized knowledge of IRS tax agency audit, collection and appeals procedures, policies and practices. In my opinion, this is generally limited to those whose practice focuses on providing the services of tax controversy resolution.
The IRS and all State tax agencies will only permit representation by individuals who are certified or acknowledged by a government agency as meeting the necessary technical (tax law and continuing education) qualifications. These individuals are Licensed Enrolled Agents (EA), Certified Public Accountants (CPA) or Attorneys. California has a special category of preparers with a title of CTEC. They have very limited representation authority and, in my experience, a very small percentage would have had inside the IRS or a State tax agency prior job experience.
Another factor to consider in deciding whether or not to retain your current accountant or preparer to represent you is whether there may be a possible or potential conflict of interest. The IRS and most state tax agencies can impose significant civil penalties against a preparer who negligently prepares a tax return. Consider this scenario. Rather than incur penalties for their perceived error, the preparer (during his or her representation, say, in an audit....) may try to shift the Revenue Agent's or TCO's focus from himself or herself to the client as the underlying cause of the tax problem or tax issue - thereby resulting in the IRS imposing a penalty on the taxpayer/client rather than on the preparer.
I have had success in obtaining client relief from potential penalties (such as the accuracy related penalty) where I was able to persuade the Revenue Agent or TCO to assert the penalty against the preparer (generally, much less in amount) instead of the taxpayer as the underlying cause for the deficiency attributable to failing to properly account for an item or items on a tax return. If the IRS proposes an accuracy related penalty against a taxpayer, I would expect the taxpayer (client) to focus on whether his or her preparer should pay the penalty if it was the preparer's oversight. I have never heard of a situation of a preparer telling a Revenue Agent, "That was my fault - hit me with the preparer penalty and not my client with the accuracy penalty." I expect such a scenario would be rare. In my 35 years inside the IRS, I cannot recall a single instance where I experienced or read about a preparer voluntarily accepting a penalty to save his or her client from an often larger penalty! Preparer penalties could lead to discipline by the Office of Professional Responsibility (OPR) - the IRS function that watches carefully over those individuals who practice before the IRS to ensure their actions are responsible and ethical.
Speaking of preparer representation, some individuals and companies who prepare returns offer "income tax audit protection" representation for a small fee as part of their return preparation package. This kind of representation - to my way of thinking - is much like an HMO arrangement. The individual or company will have all of your fees already, and there is, therefore, little if any financial incentive to make a sincere, effective effort to help you with an audit or collection matter - particularly in pursuing relief through the administrative appeal process. I have filed appeals and taken over client tax representation cases where the preparer-representative made a half-hearted effort to get relief for the client at the initial audit or collection process, but failed miserably in their efforts. In many situations, proper representation at the first level (usually Compliance with the IRS) would have resulted in resolution or settlement without the added cost of pursuing an administrative appeal.
I occasionally get the question, "Who or what is an Enrolled Agent?"
Enrolled Agents are the only taxpayer representatives who receive their right to practice directly from the United States Government. Only Enrolled Agents prove their competence in matters of Federal taxation and report their hours of continuing professional education (CPE) directly to the Internal Revenue Service (IRS). It is the individual states that license certified public accountants (CPA) and attorneys and, therefore, their licenses are state specific. Unlike attorneys and certified public accountants, who may or may not choose to focus on taxes, most all Enrolled Agents focus their practice on tax return preparation. A percentage of EA's also get involved providing resolution services in the area of tax controversy resolution - assisting clients with their audit and collection matters. Enrolled Agents (EAs) are tax professionals who are licensed by the U.S. Treasury and have demonstrated their compliance with that Department's tough standards.
If you need my services in obtaining a resolution of an IRS tax audit or State tax audit, IRS collection controversy concerning secured tax debts, and IRS audit appeal, IRS collection appeal or other tax-related problem with any income or employment tax agency, help is just an E-mail or phone call away!
From my 34+ years of inside-the-IRS experience, I can assure you that the earlier you seek and receive help for resolving your IRS, California or other state tax audit or tax controversy matter, the faster you can resume a normal life. An excellent analogy concerning a tax controversy is that an IRS tax audit and collection problem, along with those of the State of California tax agencies (FTB and EDD), and other State tax agencies, is much like tooth decay. It will just get worse if ignored. For example, a cavity that could have been fixed with a simple filling may end up requiring a root canal and a crown! Please be aware that when the IRS decides to do a "root canal" on your personal or company financial assets, they do not administer any anesthetic! It hurts! Further, recovery can take a very long time. Many taxpayers do not know that certain tax debts are ineligible for bankruptcy discharge (such as personal liability for their company's failure to pay employment taxes - referred to as a "trust fund recovery penalty" - or, TFRP for short). That means that the taxpayer is burdened with the liability for a a long time (typically 10 years, or much longer if the IRS opts to pursue a civil judgment against the taxpayer).
That is why I recommend that you make a decision TODAY to seek the services of a tax resolution specialist licensed by a government agency as meeting tough standards for representation before your IRS, CA or State income tax or employment tax issues become so serious that they will require more effort (and cost) to resolve, or they result in significant financial consequences such as wage and bank levies, liens, or even seizure of your real or personal property.
With over 30 years of IRS employment experience, I have extensive knowledge and understanding of IRS processes and procedures. This background will help me negotiate a resolution to your IRS or State tax controversy or get you through an IRS tax tax audit in the shortest amount of time with the least amount of financial impact. Effectively resolving a tax controversy, including the filing of and negotiating an IRS tax audit or IRS collection appeal on secured tax liabilities, can be - and often is - a very complex process where specialized knowledge and experience is critical to success.
Do your homework before selecting a firm to represent you!
I strongly recommend that you check out any individual or firm BEFORE you commit to having them represent you. Remember that it is YOUR LIFE - YOUR LIABILITY! You can delegate the AUTHORITY to have someone represent you. But, all tax agencies will deem YOU as solely responsible for your tax liability. Accordingly, you owe it to yourself to do some checking before retaining the services of a tax resolution specialist.
I have put some testimonials from my former clients on the website for your review.
I STRONGLY suggest you be leery of any firm that advertises or claims that they are #1 in the industry or have the greatest level of success. The IRS frowns on companies or individuals making such wild claims, and has taken action in the past where firms have made such statements - even to the point of obtaining injunctions against their practicing before the IRS.
Unfortunately, many firms make such unfounded claims as part of a scheme to attract and sign up clients. Unfortunately, they often retain far more clients than they can effectively handle. These mass-market firms also tend to have a high turnover of employees, resulting in your case being shuffled from employee to another - perhaps multiple times. Many clients of these firms end up forfeiting their retainers after they have become fed up with lack of an effective tax debt or controversy resolution service or audit representation, and just leave the firm to seek help elsewhere. Further, the lack of responsiveness by these large firms creates frustration with the IRS Revenue Agent, Revenue Officer, Tax Compliance Officer, Appeals Officer or Settlement Officer, or a State tax agent or officer, and that most often eads to further complications in the case.
I have personally taken over representation of a number of clients of these large representation firms who became very frustrated with the total lack of or poor quality of service from their representative or tax resolution specialist. In these cases, a significant part of my focus is doing damage control. That typically involves convincing the IRS employee that my focus is to facilitate the resolution of the tax controversy by providing timely and effective representation.
Many IRS employees have expressed to me that they prefer working with former IRS technical employees as these representatives fully understand the administrative process and what is necessary to get an approved resolution of a tax audit or collection matter. When I was a Revenue Agent (early in my IRS career), I know that I appreciated working with former or retired IRS agents (at least most of the time - there were a few individuals I worked with who really should have pursued a different line of work after leaving the IRS.....)
One reference source for checking out a representative is www.ripoffreport.com. It is a website where former clients of tax resolution firms have taken their time to share their experiences with the firms they selected to represent them in their tax controversy. Once you have identified a firm for potential representation, do a Google search for the company with the term "review" - it may bring up additional information that you need to consider. You can also check the Better Business Bureau for ratings. One of the large firms near me (for whom I have taken over some of their clients over the years) has a "D-" rating. You really have to ask yourself if you would want to have a company with such a dismal rating handle a matter that potentially could seriously adversely affect your financial life!
I strongly suggest you carefully research each company you are considering retaining BEFORE you make your final decision. Making a bad choice could not only cost you money, but could lead to more serious issues with the tax agencies - especially when the company fails to be diligent and timely in their communications with those agencies.
Once again, it is my firm opinion that a taxpayer should be skeptical of any firm's or individual's unsupported claim that they are a "leader" in the industry, or makes promises that sound too good to be true (such as, "We get our clients settlements that are pennies on the dollar"). That often repeated scenario generally refers to an "offer-in-compromise" - or "OIC" for short. It is a program wherein the IRS (and many states as well) will accept an amount less than what is legally owed to settle an account. I still hear and read about such wild claims in the media far too often! When I was still working for the IRS, our staff would encounter cases prepared by some of these firms that were - well, no easy way to say this - garbage! It was a royal waste of our time, and the taxpayer's money, for the taxpayer to even pursue an OIC avenue of resolution that had no hope of success.
Since I mentioned OICs, there are strict guidelines that must be met to even qualify for an offer in compromise (OIC). In my experience as an Associate Chief in Appeals (accepting or rejecting these OICs on behalf of the Commissioner) and in client representation post-retirement, a very small percentage of the accepted offers are resolved for a "few pennies on the dollar;" however, all accepted offers do result in some relief of the amount owed.
Statistically, in FY 2014, the IRS received 66,155 new offers and accepted 26,924. Unfortunately, the number of accepted offers declined by approximately 13 percent from the same period in FY 2013, when the IRS received 71,644 new offer cases and accepted 30,840 OICs. Still, the odds are good for someone who qualifies for an OIC to be granted relief.
Substantial concessions of tax, penalties and interest by the IRS and state agencies generally require extenuating circumstances - such as serious medical issues, advanced age, or actual or projected long-term unemployment by unskilled individuals. I was the approving official at the IRS for offer in compromise (OIC) cases in my jurisdiction for almost two decades, so I have a solid understanding of what is required to potentially get an offer accepted.
As for IRS enforcement, the IRS filed approximately 600,000 tax liens in 2013 and issued just under 1,850,000 levies on third parties (third party levies typically are bank levies or wage garnishments.) That is reason enough for you to be proactive in getting help NOW with your controversy before the situation gets worse!
As I had mentioned before, I recommend that you check out the Better Business Bureau before making a final decision on retaining a tax resolution specialist. Here is the link to my accredited BBB A+ report:
Another company rating service is provided by Business Consumer. Here is their assessment of my firm:
I recommend checking out any company you are considering through these two consumer services.
With today's technology, I am able to assist clients with professional tax audit representation, tax collection representation, consultation and return preparation services throughout the United States as well as abroad! As an Enrolled Agent licensed by the United States Treasury Department, I am authorized to practice in all 50 states, and to represent taxpayers world wide regardless of where they live. I have represented and assisted clients living in other parts of the world (either U.S. citizens living abroad, or foreign nationals with U.S. property interest or income) such as in Saudi Arabia, Australia, India, Belgium and Great Britain.
Remember that the help you need from a Tax Resolution Specialist offering tax services for the resolution of your IRS or State tax controversy or tax audit, any form of IRS appeal, or preparation of your current or delinquent income tax returns, is just an E-mail or phone call away! Costs of representation are tax deductible (generally taken as an itemized deduction on Schedule A, subject to the 2% AGI limitation).
If you need help or assistance with:
then I encourage you to read the extensive content on this website.
I retired in September 2000 as the Associate Chief of the Glendale, California IRS Appeals Office following many years of having held managerial and technical positions in the IRS Examination and IRS Collection functions. I have extensive inside-the-IRS experience in three operations/divisions (Collection, Examination and Appeals) that a limited number of other practitioners possess. As evidence of my success and recognition while working for the IRS, I was awarded the National Appeals Manager of the Year Award in 1997.
This extensive knowledge of IRS policies, procedures and practices has proven invaluable in helping me to resolve my clients' tax issues. I provide services to other tax professionals who are facing challenging technical or procedural issues.
The primary focus of my practice is representing clients in their IRS tax audit or IRS collection dispute, as well as in their IRS administrative appeal of a tax collection or tax audit controversy, or with their other tax problems or issues. While the IRS is my primary focus, I do represent clients in State income and employment tax controversies as well.
As a result of the depressed economy, I have been offering consultation services to guide clients who opt to represent themselves in the resolution or settlement of their IRS or state income tax or employment tax controversy problem. This service is primarily targeted to help those taxpayers who are unable to afford full representation, but need IRS tax audit, collection or appeal help or other guidance in negotiating the resolution of their tax controversy. If my clients - while trying to represent themselves with my consultation assistance - suddenly find that they are in over their head, I can quickly step in and represent them in the resolution of their tax controversy.
If you are involved in litigation with the IRS, or litigation related to IRS practices and procedures, and you are in need of an expert witness intimately familiar with IRS collection, examination and appeals functions and their procedures, then please contact me. With 34+ years of IRS service, and experience in the IRS Collection, Examination and Appeals Divisions, I am well qualified to testify concerning IRS procedures and practices - and the possible malpractice by other professionals before the IRS. I have given testimony as an expert witness in the California Superior Court.
Former IRS Collection, Audit and Appeals Experience
To give you a better understanding of my qualifications, I want to spend some time discussing my thirty-four plus years in technical and managerial positions with the Internal Revenue Service (IRS).
During my extensive and successful IRS career, I gained valuable experience in the following positions within the IRS Collection, Examination and Appeals Divisions:
The many technical and managerial positions I held within the IRS provide me with in-depth knowledge of tax law as well as the policies and practices of the IRS Audit, IRS Collection and IRS Appeals Divisions. In representing you in the professional resolution of your tax controversy - whether an IRS, FTB or other State audit or collection matter, my experience of having been on the "other side of the table" enables me to guide you through the maze of the IRS and other agency collection, examination and appeals processes. My objective, as a Tax Resolution Professional and your representative, is to use my extensive tax law knowledge and decades of IRS experience to negotiate a favorable resolution of your IRS, California or other State audit or collection tax controversy case.
To represent you before the IRS or the State of California taxing authorities (FTB and EDD, or an appeal of an income tax issue before the BOE), your tax resolution professional must be an Enrolled Agent (EA), Attorney or CPA. CPAs and Attorneys are licensed by individual States (and while they usually practice within those states, they are authorized to represent taxpayers in any state). Enrolled Agents are licensed by the United States Government (United States Treasury) and represent taxpayers in any of the 50 states as well as internationally. Further, Enrolled Agents are tax law specialists. Only a percentage of attorneys and CPAs specialize in assisting clients with resolution of a tax controversy in an IRS, FTB or other state income tax, employment tax or other type of tax audit or tax collection situation.
Why select me for the resolution of your tax controversy?
You already may have visited numerous websites in search of the right person to represent you or to prepare your returns. There are literally thousands of practitioners offering tax resolution, tax settlement and tax return preparation services. Many of these practitioners are very competent and worthy of your trust and business. Others have no business taking your money when they lack the skills, knowledge, ethics and/or commitment to do the absolute best job in representing or advising you.
In fact, one national firm had been the subject of a major investigation. You can watch the ABC special video report here: http://abcnews.go.com/Blotter/video/taxmasters-investigation-13383312. One of the former employees of this firm alleged that the company had hired numerous sales people to "sell" their services, yet failed to hire sufficient technical staff to handle their existing client base.
This type of situation WILL make matters worse for their clients as the tax agencies expect and demand timely responses. I have taken over clients from several large firms in our area where the clients told me that they were "ignored" by the firm's employees. As a direct result, the IRS and other tax agencies became frustrated and more aggressive - stepping up their enforcement efforts.
Take your time and
exercise care in selecting the right representative. There are many
good, competent individuals and firms fully capable and ethical.
Unfortunately, there are many others who will simply take your money and
fail to perform. Do your homework on the Internet by researching sites
like Ripoff Report,
Better Business Bureau and
others with search words such as "tax resolution." If
you have a particular firm in mind, type in the name of the firm and the
state. Be leery of companies with a lot of complaints - even if those
to have been adequately addressed (responded to) by the company. Folks generally will not take the
time to write an adverse rating unless they are really upset.
While I was still working at the IRS, my staff and I encountered all types of representatives. If a practitioner was really incompetent, we would contact our Washington, D.C. Office of Professional Responsibility (formerly called the Director of Practice) to recommend disciplinary action - including, where warranted, that the individual be barred from representing clients before the IRS. An incompetent representative not only fails to assist their client with a tax controversy resolution, but often makes matters worse for the taxpayer.
Determining who you should trust with your financial affairs is a major decision that you should not take lightly. I can suggest five reasons why I believe I merit your trust and confidence to help you with your IRS, FTB, EDD or other tax agency audit, appeal, tax controversy or return preparation needs.
First, I have the in-depth tax law and procedural knowledge and inside the IRS experience to effectively represent you. I understand how the Internal Revenue Service works internally and that allows me to predict how they most likely will approach your particular tax controversy, and even more importantly - how best to get you the least costly resolution or settlement of your tax controversy problem case. I know the responsibilities and settlement authority of all categories of IRS employees. I do not waste my time (or my client's money) discussing matters with employees who lack the authority to resolve a particular controversy. State tax agencies operate similar to the IRS, so my extensive IRS background assists me in working with employees from those other agencies such as the California Franchise Tax Board (FTB).
Second, I limit the number of clients that I represent. This ensures that you will always have quick access to me. Think of this scenario. You open your Saturday mail and find a threatening notice from the IRS. Understandably, you are very concerned and want to talk now - not later - with your representative about this notice. With the majority of representation firms, most likely you will be unable to talk to anyone until the following Monday (and that assumes that the individual will return your call at that time...).
As my client, you will have my home number and cell number so you can call me any time you need to discuss something urgent about your case. I access my e-mails almost hourly both during the day and and evening - seven days a week. For example, if you receive an unexpected threatening IRS Notice in Saturday's mail, we really should discuss it that Saturday - not the following week. Scan and email (or fax it) to me. I will then tell you what it means and how I plan to deal with it so you do not spend the weekend stressed out and unable to sleep or concentrate at work.
As my existing and former clients will confirm, I am almost always available 7 days a week - from early morning until late at night. I tell my clients that I do not want them stressed out over a weekend or holiday because of concern about something like a IRS tax notice they need to discuss with me. I ask them to E-mail or call me so I can give them an explanation of the Notice and to assure them that I will take whatever action is required on Monday morning.
Comments I have heard from former and current clients (who left other representatives to have me represent them) convince me that immediate availability and responsiveness are seldom attributes associated with large production-mill firms. Almost all of these firms advertise extensively on the Internet and occasionally on television or in other media such as radio. They are lightning-quick to take your hefty retainer, but then - good luck on getting them to actually help you with your tax controversy.
Here is something for you to consider. If a tax resolution company requests a very large payment up front (many thousands of dollars, for example), that may be a big warning sign to you - particularly if they offer to represent you for a flat fee. Consider this. Once they have all your money, there is NO financial incentive to provide services to you (does this sound like some HMOs?). Most reputable firms I know in our line of business will ask for a reasonable retainer up front, and then bill you for whatever services are provided in the tax resolution of your case.
If you are paying for representation, you, the client, have every right to expect timely response to your inquiries and actions on your case. That often does not happen in a large regional or national firms where each employee is burdened with an unreasonable number of client cases. Former clients of those firms who left (often forfeiting large retainers) and retained me have shared their frustration with being unable to reach their appointed representative after leaving many voice messages or E-mails. As a last resort, they go up the chain of command to their representative's superior hoping for (but seldom receiving...) a resolution of their problem.
If you have been calling one of these firms to discuss representation and not receiving a timely call-back, that should be an immediate and serious warning to you. Once they have your retainer, their practice may be to ignore you and focus their efforts in finding and signing up even more clients - in spite of the fact they have a fraction of the resources required to timely service all the clients who have retained them!
If you are currently involved with one of these large firms, have paid a large non-refundable retainer, and are receiving inadequate service, you may wish to retain me as a consultant to assist you in getting your firm to do the right thing on your IRS tax audit, appeal or other IRS, FTB or other state controversy or problem. You do need to exercise caution when deciding to simply walk away from an existing representation engagement. Many professionals have early termination clauses or forfeiture of retainer provisions in their Engagement Letters. Rather than lose your retainer, use my knowledge and experience to make them do what is right!!!
In my opinion, I represent a serious threat to any firm that is negligent in their fiduciary responsibilities to their client. I have given defense testimony in the California Superior Court in a multi-million dollar lawsuit as an expert witness in an alleged civil malpractice case involving a CPA. Use my experience and knowledge to your advantage if you have already paid a significant sum to a representative and you feel that they are not meeting their fiduciary responsibilities to you!
Whether you retain me, or some other professional, my recommendation is to stay clear of the large production-mill firms. Many have testimonials on their websites quoting a few clients for whom things went right. Do not stop there! I recommend you do some Google research on the firm. You likely will find extensive adverse feedback from their other clients. The Better Business Bureau is a good source for information on these firms as well. For instance, here is a link to one of their reports on a large firm that does an extensive amount of advertising, but (per the BBB), allegedly fails to deliver on their promise. I do not know if the firm has "cleaned up their act" or not.
One other point - if you retain my services, you and the tax agency will be working solely and directly with me - not an associate, paralegal or clerical type. In the large firms, you most likely will be working with an employee who may or may not possess the qualifications and experience to effectively represent you. And further, as I have heard about one of the large firms in my geographical area, there can be an extensive turnover of their staff.
There are a number of membership organizations that tax resolution specialists (EA's, CPA's and Attorneys) can join. For example, in addition to the basic United States Treasury licensing requirements, membership in the California Society of Enrolled Agents (CSEA) (or similar organizations of other States), and the National Association of Enrolled Agents (NAEA) means that the EA has met continuing educational requirements beyond what the US Treasury requires.
Any taxpayer seeking help should value a professional who continually strives to keep their skills sharp and current so as to provide them with the best possible representation. In keeping with this objective, I am a long standing member of NAEA (National Association of Enrolled Agents), CSEA (California Society of Enrolled Agents), as well as a former member of NATP (National Association of Tax Professionals).
What I believe is important for your consideration is:
(1) that your representative is properly licensed,
(2) is an active member of recognized professional societies,
(3) has the technical skills and experience to maximize the probability of a cost-effective tax controversy resolution, and
(4) has no or very few complaints made to the Better Business Bureau or other rating sites.
Everything else being equal, I suggest that a representative who has had extensive and successful experience within the Internal Revenue Service should have a better understanding the inner-workings of that agency including its directives, policies and procedures, and thereby would have a higher probability of negotiating a more expeditious and favorable resolution of a tax controversy. Again, this is strictly my opinion - and a factor you need to weigh in making a decision for representation.
I do need to state for the record that past employment with the IRS (or a State tax agency) is NOT a guarantee that the individual is best suited for your particular tax dispute. In fact, I have encountered a few former IRS employees - both while I was still working for the IRS as well as post-retirement - who I believe have no business representing taxpayers. By the same token, I have experience in meeting and working with some representatives who are very skilled and competent in IRS and State collection and audit representation who have had minimal or no inside experience as an IRS, FTB or other state tax agency employee.
Finally, my clients appreciate the fact that I am available most nights and weekends for priority matters. As stated previously, my clients have my personal cell and home phone numbers so they can always reach me to assist them with any sort of emergency situation (such as a Notice of Levy or Federal Tax Lien that arrives on a Saturday). This level of access gives my clients piece of mind knowing that I am just a quick phone call or E-mail away. You will have to decide just how important it is to having immediate access to your professional representative in pursuing the prompt and effective resolution of your IRS or other agency tax controversy! Most practitioner offices are closed after hours and on weekends with limited or no means to contact your representative.
Third, my service fees are among the lowest in the industry. Why? I can give you several reasons:
Fourth, I encourage my clients to do as much of the preparation work (following my guidance) on their case as possible. Why pay me (or any other professional) to create adding machine tapes of receipts, or to fill in basic information on forms? You should NOT have to pay a professional to do these simple tasks! What you need tax resolution assistance for are the following:
Many of my clients have significant liabilities with the IRS or other tax agencies - and often hefty debts with other creditors. The absolute last thing they need are expensive representation fees to add to their financial burden. Therefore, I strive to find ways to help clients conserve their precious resources by encouraging them to do as much "leg-work" on their own case as possible. That minimizes the fees they have to pay for my professional services in tax representation / tax controversy resolution.
One way I accomplish this for my tax controversy clients is to provide them with both the required and current PDF fill-in forms, along with guidance for their completion. Once my client completes and E-mails me the forms, I carefully review them for errors, inconsistent or unclear entries, and then work with my client to make whatever changes are necessary, or additional attachments that I deem are necessary to ensure favorable acceptance by the tax agency.
I want to stress that all of my clients work EXCLUSIVE WITH ME - not with an assistant or clerk. That is not a standard practice in the industry with large firms. The CEO, CFO or other head person for a firm may be well qualified; however, is it unlikely (in my experience) that they ever will be personally involved in your case - unless something goes terribly wrong and you end up complaining. So, I suggest that is a factor that you need to carefully consider.
My clients appreciate the opportunity to minimize their total cost for my services to just those specific areas (such as face-to-face or over the phone negotiation with the IRS or State agency) where they really need my skills for resolving their tax controversy.
Finally, it is important that your representative keep current on new tax developments - legislation, litigation and tax agency procedural changes. As mentioned previously, I subscribe to CCH Intelliconnect - a well-known and highly respected tax service. In fact, the CCH resource service is used inside the IRS by their technical employees and outside of the IRS by professionals searching for the right answer to technical and procedural issues. I used CCH for most of my IRS career.
As part of the CCH service, I receive daily updates (tax law changes, court decisions, tax agency procedural changes, etc) in the areas of my practice so that I can continue to provide the best possible service to my clients. I also subscribe to DataQuick - an online service that provides invaluable information to help in the resolution of tax disputes. Without these tools, no representative (in my opinion) can effectively represent you before the IRS - or any other tax agency.
In addition to this research service, I often attend the annual CSEA Super Seminars in Las Vegas. This is an outstanding opportunity for me and many other EA's, CPA's and attorneys to keep abreast of the latest trends, laws and procedural updates through presentations from highly respected tax attorneys and other professionals from around the U. S. I also am an active member of the National Association of Enrolled Agents and the California Society of Enrolled Agents. These organizations provide valuable materials, updates and resources that assist their members in providing their clients with effective representation and guidance.
I hope these five reasons merit your confidence in my ability to effectively represent you in your IRS or State tax controversy, or to provide you with tax preparation or consultation services. I take my representation responsibilities to my clients very seriously. Much of my practice is based upon referrals. Working closely and effectively with clients in getting them the best possible resolution or settlement to their tax controversy is the most effective means to grow a business based upon client recommendations.
Tax Practice Areas
The four broad categories of services that I offer are:
Tax Return Preparation
There are many self-help income tax return preparation products on the market today for preparing your 1040, 540 and other tax returns. Some of these products are actually quite good - particularly if you have some basic understanding of income tax law. Two of the better-known products use the interview technique to guide its user through the process of preparing their own income tax returns for the IRS and their State.
While the interview concept is generally effective, the potential for error still exists because of the technical complexity of the subject matter of some interview questions. A wrong response could result in an erroneous reporting of one or more transactions - and that could lead to an audit which, in turn, will likely result in additional tax, penalties, and interest - as well as representation fees for resolution of the income tax controversy.
To illustrate a complexity of the law, here is a simple - but not uncommon - situation. If you receive a piece of property from a relative - by gift or bequest - do you know what your basis (cost value) will be when you sell it? Your basis will be different depending upon whether you received it as a GIFT or by way of an INHERITANCE. If by mistake you use the wrong basis, you will either pay too much income tax (which the IRS or FTB likely will keep unless you find out about the error and file an amended return within the statute of limitations period), or pay too little tax and end up owing the IRS/FTB a bundle (including interest and maybe penalties) when they catch up with you for an audit.
The tax resolution specialist fees associated with defending you in the resolution of a tax controversy before the IRS or FTB because of errors in your income tax return most likely will end up costing you many times the savings you believe you will achieve by preparing your own tax return.
You also need to aware that selecting a low-cost service that cranks out income tax returns like a puppy mill may result in adverse financial consequences for you if your tax return is inaccurate. Some of these types of firms get targeted by the IRS (if the firm makes an unacceptably high number of errors on clients' returns that is discovered during return processing or audits), and then ALL of their clients get audited! My advice to you is to stay clear of firms owned or managed by an individual who is NOT an E. A., CPA or Tax Attorney.
It is also important to inquire about the qualifications of the person actually doing your return. Please consider the potential for error if they have a very limited, shallow exposure in tax law. Several large chains hire seasonal people and give them a "crash course" in tax law just before the filing season. While the manager or owner of the company may review and even sign the return, that person was not present when your interview took place, and would be unable to know if a response you made really needed to be analyzed more closely to identify items that should be on your return or should receive special treatment!
Below are some warning signs that if they appear during your conversation or meeting with a tax preparer, you need to grab your documents and run! Be very cautious if the preparer:
There is no such thing as "standard amounts" the IRS or FTB allows you (other than the Standard Deduction if you do not itemize).
Please understand that intentionally overstating your deductions (or not reporting all of your income) for the purpose of reducing your income tax liability (to either generate a larger refund or reduce the amount you owe) can have serious consequences.
I always recommend minimizing the probability of an IRS audit (or FTB or other state agency audit), with the possible assessment of additional tax, penalties and interest by having your income tax returns prepared by a tax professional who is an Enrolled Agent, or by a CPA or Tax Attorney who specializes in tax law. Each of these three classes of professionals, particularly if the specific individual you chose to prepare your income tax return is also a Tax Resolution Specialist with extensive experience in representing clients, can best prepare your return. Further, if your tax return is selected for a tax audit, any one of these three categories of individuals is legally qualified to represent you for an audit in the resolution of your tax controversy and, if necessary, through the administrative appeals process. Whether or not you actually will use the preparer is something to consider as I discussed previously. Not all preparers actively represent taxpayers in audits or other controversies.
As both an Enrolled Agent and a Tax Resolution Specialist, I am available to prepare your Federal, California and other State personal income tax returns based upon the information you provide. For those of you who have limited (or no) Internet access and also have mobility problems, I am available to travel to your office or home if you are within a reasonable commuting distance of Burbank, CA.
With the growing number of individuals using the Internet, the vast majority of my clients are pleased to have me prepare their returns using E-mail (with attachments) and the Web. My furthest tax return preparation clients are United Kingdom citizens (who own rental property in Florida). I have been able to assist them for many years in meeting their 1040NR filing requirements via the Internet even though we are thousands of miles apart!
To illustrate how I use the Internet, after receiving the Engagement Letter and deposit, I E-mail my client a password-protected Tax Organizer. My client completes the Organizer and E-mails it back to me. The required documents (W-2's, 1099's, 1098's, prior year federal/state returns, etc.) are either scanned and E-mailed, or faxed/mailed to me. I review their organizer, any questions they have given me, their information documents, and then follow-up with any questions I have following my review that require clarification.
Once this process is completed, I draft the returns and E-mail PDF (Adobe Acrobat) drafts to my client for review. Once my client approves the draft and sends me the balance due (by check, credit/debit card or by PayPal), I finalize the returns, get their signature on the e-file authorization forms and the Statement of Accuracy (attesting to their careful review of their returns), and e-file them. If my clients prefer, and execute the required forms, I will mail them their original returns for manual filing.
My clients have told me how great it is to be able to use the Internet for this entire process. It saved them from having to take time off from work, travel time to and from my office, and travel costs (the latter can be very significant depending upon current gas prices)!
Many of my clients utilize Pay Pal (many people already use Pay Pal for eBay and other online activities) for payment of retainers, preparation, consultation and tax controversy representation fees. I also accept four major credit cards for retainers and all services, giving clients the ability to spread out their cost for representation or preparation over a number of months, if necessary.
Tax Controversy Resolution (representation before the IRS or State Agencies)
If you need IRS tax audit help or IRS collection help - or tax audit or collection help with any state tax agency, this is the primary focus of my tax practice. Trying to resolve an IRS audit or collection matter without professional assistance will be a challenge.
Having said that, I strongly recommend that you consult a tax resolution specialist or other tax professional before responding, and certainly before sending information or additional money to the IRS. It is not uncommon for errors to occur in the amount that IRS, FTB, EDD or other tax agency claims you owe. Please keep in mind that as an Enrolled Agent, I can represent you at an IRS, FTB, EDD or other state audit, collection or appeals without you having to take time off work to attend meetings or conferences.
Just as important as it is to have your income tax returns prepared by someone who understands the tax law, it is just as important to be represented in the resolution or settlement of an IRS or state tax controversy, whether it is an IRS tax audit, or audit by the FTB or State tax agency, by a tax resolution specialist who, as your advocate, is skilled in understanding and presenting the facts and law as they apply to your case. As mentioned before, I am authorized to represent you and negotiate a resolution of your tax controversy case before the Collection, Examination (Audit) and Appeals organizations of the IRS, as well as all of the State of California and another State tax agencies.
My goal will be to obtain resolution of your tax controversy on the most favorable basis possible. The primary focus of my practice as an Enrolled Agent and Tax Resolution Specialist is working and negotiating with the IRS Audit, IRS Collection and IRS Appeals organizations. I fully understand their processes, the Internal Revenue Manual, as well as the evaluative performance criteria for IRS personnel. All of this information is very important to effective resolution of your tax controversy by negotiating on your behalf during an audit, the appeal of an audit, an Offer in Compromise or any other IRS action.
I always recommend that taxpayers get IRS tax audit help rather than try to represent themselves. The money you think you are saving by not hiring a professional to represent you may well be far less than the amount of tax, penalties and interest you will owe if mistakes are made in the audit process.
The FTB, EDD and other State tax agencies operate similarly to the IRS, although there are differences in a number of areas (such as with the Franchise Tax Board in pursuing an administrative appeal of a field decision). Given my extensive IRS background, I am easily able to transfer that knowledge and experience in helping a client with a State tax issue.
My Background in Appeals
Almost all of my clients are unfamiliar with the internal operation of the IRS, and do not understand just what my duties and responsibilities were in my IRS Appeals Associate Chief position - and how this knowledge and experience can assist me with the resolution of their tax controversy. Allow me to give you some background information. During my tenure as an Associate Chief of the Los Angeles and Glendale Appeals Offices of the IRS, I was the deciding official responsible for accepting or rejecting proposed settlements of Collection enforcement actions, Examination Division tax return audits and Service Center generated issues (correspondence tax audits and assessed penalties) that were negotiated by our staff of Appeals Officers and Settlement Officers.
The IRS Collection cases involved common issues such as collection appeals of liens and levies (CAP) cases, offers in compromise (OIC), collection due process (CDP) cases, trust fund recovery penalties (TFRP), assessed penalties and payment agreements. Examination cases covered just about every aspect of the Internal Revenue Code, ranging from issues typically found in individual audits (such as unreported income, itemized deductions, activities not engaged in for profit, employee business expenses, etc.) to the heavy corporate issues (excessive compensation, accumulated earnings, reorganizations, abandonment losses, etc.).
As the Associate Chief, I had to evaluate the evidence as developed by the IRS Revenue Officer, Revenue Agent or Office Auditor (now called a Tax Compliance Officer) in support of their position, as well as additional evidence submitted during the Appeals consideration by the taxpayer and/or his representative to rebut the IRS's proposed adjustments. Upon conclusion of the negotiations in Appeals by my employee, I reviewed the settlement proposal (or recommendation for litigation) prepared by the Appeals Officer or Settlement Officer.
As part of this review process, I may have had to consider the credibility of all parties who were likely to testify at trial if the case proceeded to litigation. Following my review, I made the final decision regarding the disposition of the case by the Appeals Division. This typically resulted in my:
Please consider the potential financial impact of trying to handle your own tax controversy case, or selecting an advocate who lacks the experience and qualifications to adequately represent you in a collection action or tax audit. Tax laws are very complex, and understanding both the tax laws as well as the tax agency's administrative procedures are of crucial importance in negotiating a resolution of your tax controversy.
Tax controversy resolution is my specialty area of practice, so please do not hesitate to contact me for further information and assistance.
Has the IRS or one of the State taxing agencies sent you a Notice of Adjustment, Notice of Examination, Notice of Deficiency, Notice of Intent to Levy or any other type of communication? Do you owe back taxes? Have you not filed returns for many years? Do you want to know what options you have, and get a recommendation about how to proceed from a tax resolution specialist who is very knowledgeable about and experienced in working with IRS and State processes and procedures? Are you unable to afford full-representation costs, but are in a position where you must negotiate with the IRS, but you really need a professional to guide you through the process?
I am available for either telephone or in-person consultation. Your initial E-mail (not office) consultation for providing general information regarding an IRS or State Notice or Examination Report, or for your potential qualification for an Offer in Compromise, is free. For example, you just received a notice from the IRS (let's say a CP504 notice). What does that notice mean? What notice or action will likely follow? The free consultation is to give you general information that is not specific to your tax returns or financial condition.
For specific advice on your personal tax controversy, I do charge for my services. A specific tax question might be along this line: I have a business that the IRS says is an activity not engaged in for profit. How do I persuade them otherwise? To answer that question, you will need to provide me with specific information about your business, such as its history of profits or losses, your past experience with the product or services you provide, your success in other ventures, the formality of your record keeping system, and so forth.
For telephone, E-mail or in-person specific consultation, you may purchase one hour of consultation time - typically sufficient time for providing you with specific advice on how best to proceed in resolving your tax issue and respond to questions along the way. In advance of our consultation, I will ask you to E-mail or fax me specific documents I will review so as to have an opportunity to review and consider your tax controversy or concern before our consultation time.
Your telephone or E-mail consultation fee is payable in advance either by check, money order, credit/debit card or through PayPal. If you subsequently retain me to represent you for the resolution of the issue, then any unused consultation time (up to one hour) will be applied toward your retainer. Further, if you retain me to represent you and our engagement is fully in place within 7 calendar days of your consultation date, then at your request, your one hour consultation fee can be applied to your representation retainer - thereby making your one hour consultation free!
Office consultation also is available (for example, you have a lot of documents that I need to review). For all office consultations, I charge my normal fee, and payment for the minimum one hour's time is required before the consultation date. If after our consultation you decide to retain me for representing you, then I will apply any unused portion of your consultation fee (up to one hour) toward your representation retainer.
Please check out my Consultation page for more details.
Expert Witness/Litigation Support
I have given testimony in the California Superior Court as an expert witness and provided declarations in litigation cases. If you find yourself in need of an expert witness who has in-depth inside-the-IRS knowledge, please contact me so that we may discuss your needs and how I may be of assistance in providing you with litigation support.
Do you want to know more about the rules for deducting a home computer used by an employee who uses one in their job? Are you interested in finding out if you would qualify for an Offer in Compromise? Do you believe that you may be an "innocent spouse" and therefore, not liable for a portion of a joint deficiency with your ex-spouse? What are the rules for paying the "nanny tax?" Do you have some other tax question for which you need further information?
There is a large section of this web site devoted to addressing these and many other recurring tax issues of interest to most individual taxpayers. In addition to the above items, topics addressed include Collection Due Process procedures, installment agreements, contributions of property (you most likely have heard all of the radio ads advertising large deductions for donating your car that needs repair and cannot be sold ... be careful on this one!!.) - and the list goes on.
If you are interested in reviewing the index of topics, click here or click the Technical Topics button on the index bar. There is also a link to the index of technical topics on the Representation web page.
I welcome your Email (firstname.lastname@example.org or email@example.com ) or phone call with your questions or comments. There are also links at the top and bottom of this home page to another page where you can submit a general tax question.
I encourage you not to attempt negotiating on your own with the IRS or State Tax Authorities in your tax controversy unless you have a solid knowledge of tax law and understanding of the processes and procedures of IRS, FTB or other State Tax Administration. Believing that you can save money in a IRS tax audit or collection action or appeal (or a similar action by the FTB or other state agency) by not engaging the tax services of a qualified tax resolution specialist could end up costing you significantly more in the end than the representation fees you save.
However, I recognize that in this recessionary economy, there are many taxpayers in serious trouble with a tax agency, but financially who are unable to afford full representation. If you are one of those taxpayers, and you feel that with guidance you are up to dealing with the IRS, FTB or any other tax agency on your own and just need someone intimately familiar with the law and procedures to guide you, review documents, etc, then we should certainly talk. I typically have several clients at any one time who are going this route as a means to resolve their tax controversy while trying to keep their costs to a minimum. If you opt to go down this path and at some point the path gets too rough and you need me to jump in and get the resolution process back on track, I will be on standby and available to take over if necessary.
Certified Tax Resolution Specialist (CTRS)
I have had some inquiries about what the term certified tax resolution specialist or the acronym CTRS means. What does the term "certify" mean? In one dictionary, the definition is given as "Officially recognize (someone or something) as possessing certain qualifications or meeting certain standards."
From my review, the CTRS (this acronym according to one source has 35 different meanings....) - designation to represent a certified tax resolution specialist is offered by a private organization (non-governmental) - American Society of Tax Problem Solvers (ASTPS) - to its dues-paying members who are an EA, CPA or attorney and pass what I understand to be a non-proctored exam. However, the "real" certification that is most important to prospective clients is the one required of practitioners by the U.S. Government - that of being an Enrolled Agent, CPA or Attorney - all of which require the passing of a tough exam (or in the case of an EA in lieu of the exam - having extensive and successful IRS technical experience for a minimum number of years), and meeting continuing education requirements.
As an IRS manager, the designation of a representative as a certified tax resolution specialist (CTRS) was of no significance to me. Unless the representative was an EA., CPA or an Attorney, the individual was prohibited to represent a client. Does it hurt to have the certification as a Certified Tax Resolution Specialist - CTRS? Of course not. For those individuals who are embarking on a career as a tax resolution specialist who have no or minimal inside-the-IRS technical experience as a Tax Compliance Officer, Revenue Officer, Revenue Agent, Settlement Officer, Appeals Officer or Attorney with Area Counsel or the U.S. Attorney's Office (DOJ), getting all of the focused knowledge they can will only make them better at the complex job of effectively representing clients. From reviewing the website of The American Society of Tax Problem Solvers (ASTPS) organization, they appear to offer courses that would help anyone new to the practice of representing clients before the tax agencies. They certainly are not the only source for specialized education - there are numerous entities offering continuing professional education both necessary and helpful to those in this specialized field. CSEA, for example, offers interested individuals focused tax courses annually in Las Vegas (called the 'Super Seminar").
It is absolutely essential that individuals who offer their resolution services to assist clients with the tax resolution problems have the requisite education and experience to be successful. The United States Treasury has established minimum continuing education requirements for licensing Enrolled Agents (as have the CPA and attorney state licensing boards). NAEA and CSEA - two major membership organizations - have even greater educational requirements for its dues-paying members. EAs and other members of these organizations (typically CPAs and Attorneys) have the requisite educational skills to represent clients in providing a service to assist in the tax resolution or tax settlement process.
While obtaining the CTRS designation by paying membership dues and passing the test administered by ASTPS will not hurt, it is my opinion that it does not in and of itself guarantee that the individual can effectively provide the resolution or settlement service that is necessary to ensure a successful outcome. Last time I checked, only one year of experience was required for being permitted to use the CTRS designation. That may have changed. Continued education is vitally important, and is mandated by the IRS as well as most all of the membership organizations - including ASTPS who administers their certified tax resolution specialist program and offers its dues-paying members use of the CTRS designation.
It is my opinion that what is far more important than the CTRS designation is the experience and success the representative has had in real-world negotiations with the IRS and state tax agencies. I offer for your consideration that a properly government licensed professional who also has had significant inside-the-IRS technical experience would be worthy of serious consideration to handle your tax resolution controversy whether it be in the areas of collection, audit or appeal.
I want to ensure that all who visit this website understand that the tax laws apply to everyone in this country, as well as to individuals outside of the United States who earn money from investments, property or businesses located in the U.S. (unless specifically exempted by a tax treaty, or specific provisions of the U.S. Internal Revenue Code).
Filing returns and paying the taxes when due is required by law. The willful failure to file a return and/or pay your income or business tax can result in not only civil penalties, but criminal prosecution and penalties as well - and that can include prison time! This is serious stuff!
Please - don't be fooled by individuals who try to convince you that you can beat the system. Following their advice will most certainly cost you dearly in the end - not only in your pocket book, but possibly your freedom and reputation as well.
The IRS put together a document that discusses the most common contentions by tax protesters, and the legal basis proving their contentions false. I have uploaded this document to this website for your reading.
If you are contemplating not filing returns or paying the tax based upon something you heard or read that allegedly exempts you from the process or tax system - or have not filed before now because of what you heard or read, I strongly recommend you read the IRS document hyperlinked below before you get into a serious situation that can adversely affect you and perhaps your family as well. Please share this web site information with any family, friends or work acquaintances for whom it will be meaningful.
Here is the link to the IRS document.
The IRS issued a notice in 2006 providing further information on this topic. Here is the link to Notice 06-31.
In fact, each year the IRS has provided information concerning the most recent (as well as historical) positions taxpayers have taken that lack basis in fact or law. Here is a link to the IRS release of such a document in 2015. If you think that you are exempt from filing tax returns and paying any resulting income tax that may be due, I STRONGLY recommend you read CAREFULLY the information provided - otherwise, you could find yourself in a very precarious position - including spending time in prison!
If you have not filed all of your required returns, I recommend you engage the services of a tax resolution specialist certified by a government agency as an EA, CPA or Attorney to get them prepared and filed ASAP - and hopefully you will do this BEFORE the IRS comes after you. In my several decades of IRS experience, I never heard or read about a prosecution of a taxpayer who came forward and voluntarily filed delinquent returns (before IRS contact) in their effort to get compliant with the tax laws.
Please understand that if you have not filed one or more tax returns, depending upon the circumstances for non-filing, the US Attorney may be able to convince a jury that your failure to file was not due to negligence or oversight, but solely for the purpose of willfully evading the tax laws. This is why it is so important that even if you are unable to pay the tax liabilities and penalties for your delinquent returns, file the returns!!! I can almost always work out a deal for you to satisfy the liabilities by an installment agreement, an Offer in Compromise or another form of resolution.
This is important! If you are contacted by a Special Agent of the Internal Revenue Service (or otherwise notified of a pending criminal investigation), I strongly recommend you retain the services of a qualified tax attorney - immediately! I will be happy to recommend one if you need such a referral.
The United States Tax Court and other Federal Courts have the power to assess sanctions against a taxpayer - and their representative - who advocate tax protester type arguments. Here is an excerpt from a 2007 9th Circuit Appeals Court case on this point:
Taxpayers who pursue these meritless arguments not only end up paying the tax in the end, but incur legal fees in the process, AND - as in the case above - significant additional costs.
Please - do not risk becoming an IRS prosecution statistic because of delinquent returns! Contact me and I will work quickly with you to complete your delinquent returns and get them filed. If you believe you cannot pay all of the tax, penalties and interest you will owe, do not let that aspect delay the filing of your delinquent returns. Once filed, we can explore alternative payment options with the IRS and State tax agencies such as an installment agreement, an offer in compromise or the status as currently not collectible as mentioned previously.
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