IRS AUDITS AND EXAMINATIONS

From substantiation cases to complex partnership adjustments, including eggshell audits where criminal exposure is on the table. We handle IDR responses, summons enforcement, and protest strategy.

Petitions, motion practice, discovery, stipulation, trial, and post-trial briefing. Over 80 cases as counsel and six trials since 2022.

Preparing expert reports and witnesses for Tax Court trial. We work with valuation experts, economists, industry experts, and accounting experts on damages, substantiation, valuation, and reasonable-compensation issues, and we advise on the new and under-discussed risk of AI-contaminated expert work. 

Strategy, protest and briefing, and settlement negotiation before the Independent Office of Appeals — including Fast Track Settlement and Post-Appeals Mediation where appropriate.

Imputed underpayment defense, push-out elections under IRC § 6226, Section 6225(c) modifications, and BBA partnership audit and collection strategies.

Installment agreements, Offers in Compromise, Collection Due Process, innocent spouse relief, and currently-not-collectible status. Strategic sequencing for clients with both assessment and collection exposure.