We have a 99% success rate. It would be 100% except for one representation where we offered the government 750 million in cash to settle the matter and the government passed! The case may be tried in the Tax Court late this year. Except for that one miss we have reached agreement with the IRS in every case.
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 thirteen 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 thirty 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, met with the examiner and IRS management. The entire process lasted 44 days and the returns were "no changed."
A large high tech company faced with a 24-month examination we met with the Exam team and IRS management. With good examination, 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 that fifty million dollars. The director’s determination resulted in no tax due.
When you get the appointment letter to start an examination, we assist be 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 a 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 hardbargain 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 except. 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 Examanination 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 only is 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.