The components of my practice include  IRS Representation and  Tax Preparation, planning and business consulting.
♦ IRS Representation
Authors of a recently published treatise on tax practice and procedure in defining tax controversy stated “that it begins as early as pre-controversy tax advice and the opinions provided prior to taking positions on tax returns.” It is useful for clients and taxpayers generally to know what is meant by the term “positions” taken on a tax return and even better the positions taken or planned to be taken on one’s own tax return. With the possibility of IRS challenge in mind, from this starting point an understanding of how to defend such positions may be gained.
In the event a return is selected for examination once the return is filed, it is important to timely respond to notices received. Consideration of the amount of time required to evaluate the matter, gather the necessary documents requested and prepare is a critical step in the process that will likely affect the outcome of the IRS inquiry. Consideration of penalty exposure is also a relevant part of this task. These matters are also part of the pre-controversy task list.
Effective representation given the complexity of today’s tax laws is a process not an event that requires collaboration between the client, accountant and possibly the transactional attorney before decisions are made and time becomes a critical issue. I work with clients to help them with early stage transactional planning, tax preparation, certain tax examination issues and when needed on tax collection issues.
A brief summary of selected tax controversy tasks include:
- Initial reading and consideration of IRS notices and correspondence received to identify issues, response due dates, know what information is requested, and consider other relevant tasks as appropriate
- Determination in collaboration with my client, how best to respond to IRS notices, whether timelines are realistic, whether the documents or substantiation requested is available, assist in organizing documents requested to facilitate understanding by the IRS
- Identifying problematic tax positions taken, if any on prior returns
- Evaluating tax positions during the course of preparing the current year return
- Advising clients about and consideration of corrective reporting or disclosure
- Responding to IRS notices and inquiries in respect to unpaid tax liabilities
- Evaluating client’s ability to pay as an unpaid liability proceeds to collection
- Negotiating regular installment agreements
- Assisting clients with their preparation of Collection Information Statements for themselves individually and the business if needed including an evaluation of supporting documents to amounts shown and an consideration of cash available for paying the planned installment payment agreement including the tax effect of such cash in future years for the purpose of avoiding a failure to comply with its terms.
- Compliance monitoring of current and future tax obligations to avoid default and possible termination of effective installment payment This may include evaluation of unexpected issues that may arise during the course of the agreement which could adversely affect agreements made in prior years. An example of this may be an unexpected downturn in one’s cash flow or business that reduces cash allocated to service the agreement.
♦ Tax Preparation, Tax Planning and Business Consulting
In general terms this service area involves working with individuals and their families with respect to tax issues affecting their personal, business and real estate interests. Tax planning and advisory services usually result in positions taken on a tax return. The due diligence required by professional standards in part involves a proper identification of transactional facts, identification of appropriate authorities, analysis of such authorities and documentation of conclusion reached.
During the course of representation, while I try to provide informative explanations with respect to certain relevant matters, I have found the best result is reached when working collaboratively with my clients in connection with the subject task or engagement. Our mutual discussion of the information you provide is important to achieve accurate tax reporting.
I know that the cost of accounting services is a concern of everyone walking into my office. Where I feel it is possible, services are fee based so that the cost is known before work begins. If I do not have a basis for setting a fee, then costs are based on the amount of time spent on the engagement. Professional fees are then billed at our set on an hourly rates which are discussed with my client in advance of starting the engagement.
Some examples of services provided and issues addressed in this category of services include:
- Entity choices for your business operations and capitalization planning
- Tax return preparation and tax planning for the current year tax liability
- Consulting and advisory services in respect of bookkeeping duties
- Wealth and succession planning strategies
- Advisory service regarding business capitalization
- Consideration of business compensation structure for officers
- Advisory services in respect of debt repayment strategies
- Charitable contribution planning
- Retirement planning including consideration of the amount of money you will need to retire comfortably
- Analysis of wage withholding for federal and state income taxes
- Determining required quarterly estimated tax payments based on expected taxable income
- Consideration and analysis of pending business transactions
- Plan for your expected future year tax liabilities
- Required substantiation for tax positions planned in the current year