1. Why choose me to resolve your tax problem?
My Appeals background, knowledge of the IRS, negotiation skills and passion sets me apart from other tax professionals in the tax resolution industry.
I have extensive tax resolution experience across a wide range of tax issues gained from 25 years as an appeals officer. Helping people resolve their tax issues was a gratifying experience for me with the government and it continues to motivate me now in private practice. My Appeals background and skillset sets me apart from other tax professionals in the tax resolution industry.
2. Why is having a tax professional with an Appeals tax background important to me?
Appeals has settlement authority that binds IRS Exam and Collection and taxpayer to the negotiated settlement terms and brings closure to the appealed issue(s). IRS Appeals is where tax issues have the greatest opportunity for case resolution. Issues that cannot be resolved in Appeals may be challenged by a taxpayer in the Tax Court.
As a former Appeals Officer, I resolved tax disputes through legal analysis of the issue and used any relevant IRS rulings and outside court cases to determine a settlement range of the issue for the taxpayer.
3. Why are negotiation skills important to me?
Because the optimal case resolution for a taxpayer requires fully understanding the substantive merits of an issue in order to negotiate effectively with the Appeals Officer.
4. Why is knowledge of IRS Appeals and the judicial system important to me?
Because I understand the unique role of Appeals within the IRS and the outside judicial system. There is often a direct correlation between how an issue is settled in Appeals and how the Tax Court might view the issue. Given this uncertainty, it is in the best interests of the taxpayer and IRS to settle a dispute in Appeals because of the “hazards of litigation” – the probability of prevailing on the issue in court for either side.
5. When should I dispute a tax issue?
The best time for you is during the Examination process and you believe that the adjustment may not be correct based on incorrect application of the law or believe that other factors should be considered by the examiner or IRS Service Center but were not.
If you are in the Collection phase, your options for case resolution are limited to tax balance payment options – extension to pay, installment agreement and offer in compromise (OIC).
6. What can I expect if I hire you?
Depending on the particular facts of your case, you can expect that I will work hard to resolve your case. I will negotiate the best possible settlement of your case with the IRS.
7. What can I expect if I contact you?
I will schedule 30 minutes for you to discuss your particular tax issue with me that will enable me to understand your issue and whether I may be able to help resolve it for you.
To get the most from the call, you should be prepared to provide me with as much details and specific information about your issue as possible.
8. What specific resolution services or areas of resolution can you help me with?
See my Services section. These are just some of the areas of tax resolution services I provide. Other service areas I provide include the assertion of the trust fund recovery penalty (TFRP) against the “responsible person” of a business and innocent spouse claims for relief from joint tax liability. When you file a joint tax return, each spouse is legally responsible for the entire tax debt, even if you divorced after you filed a joint tax return.
Some of the ways you may become aware of such liability is:
- The IRS is examining your tax return and proposing to increase your tax liability
- The IRS sends you a notice
You must generally request relief from joint liability by filing Form 8857 no later than two years after the date the IRS first attempted to collect the tax from you.
In the TEGE area, I can help you with the application process for tax exempt status and even help decide which particular Code section might be best to apply for to optimize your chances of IRS approval of your application.
9. What else should I know here?
It is important to know where your particular case is with the IRS as there are different “stages” within the IRS that a taxpayer’s case moves through. Do not ignore any letters or notices you receive from the IRS! This is a sure way for you to expedite the IRS collection process where your ability to challenge the underlying tax liability is essentially foreclosed. By not acting during the examination process when you could have, you are deemed by the IRS to have exhausted your available administrative remedies.
Generally, the earlier you resolve your case with the IRS the better for you. The longer you delay attempts to resolve your case, the more interest and penalties will accrue for the unpaid tax. Do not wait until IRS issues a Notice of Deficiency (NOD) to you because your only option at that point is to full pay it or contest the matter by filing a petition with the Tax Court. If you opt to challenge the NOD in court, the IRS is presumed to be correct and you bear the burden of overcoming that presumption in court.