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Documented Positions
An IRS or state audit is not random. It is a data-driven inquiry into whether your tax positions are substantiated. Our IRS Representation practice defends entities and high-net-worth individuals facing examination.
We act as the primary interface between you and the tax authorities, managing all correspondence, documentation requests, and field interviews. Our goal is simple: to protect your interests, substantiate your positions, and reach the most favorable administrative settlement possible without unnecessary litigation.
How we deliver this service.
A rigorous, phase-driven process ensures nothing is missed and every position is defensible.
Notice & Risk Analysis
We review the IRS notice (CP2000, CP501, etc.) line by line to identify what triggered it and the scope of the examination.
Power of Attorney (POA)
We file Form 2848, making US/UK Cross Border Tax your official representative. The IRS then deals directly with us, not you.
Document Substantiation
Our team compiles a complete, organized working paper file that maps your source documents directly to the line items under review.
Technical Memorandum
For complex positions, we draft a written technical memorandum citing specific IRC sections and Treasury Regulations to support our filing.
Direct Negotiation
We handle all meetings with the Revenue Agent, defending your positions and resolving technical disputes at the field level.
Final Settlement
We review the Agent's report (Form 4549), check that the agreed adjustments are accurate, and file appeals for any disputed items.
Institutional Defense
Controlling the flow of information from day one.
A good audit outcome depends on controlling the flow of information. We manage all Information Document Requests (IDRs) so that every response is precise, relevant, and supported by legal authority. As the single point of contact, we stop the fishing expeditions that turn a narrow examination into a multi-year audit.
Our team knows the Internal Revenue Manual (IRM) in detail, along with your rights under IRC § 7521 and § 7525, including the right to confidentiality and the right to representation. We enforce those rights at every stage of the process.
Strategic focus: IDR management, field interview preparation, IRC § 7521 taxpayer rights protection, and work-product privilege maintenance.
Tailored for every client profile.
Notice Compliance
Putting a person on the other side of an automated notice.
The IRS issues millions of automated notices (AUR) based on 1099-matching algorithms. These notices often contain errors or miss tax basis and offsetting entries. Ignoring them leads to automated assessments and eventually levies.
We respond to CP2000 and other automated adjustment notices with structured rebuttal packages: the missing documentation, corrected basis calculations, and a resolution of the discrepancy without a full field audit. Handled early, this saves thousands in unnecessary taxes and penalties and closes the file for good.
Notice specialization: CP2000 underreporter, CP501 collection notices, and Form 8275 written disclosure statements for reportable positions.
Administrative Appeals
Challenging penalties with reasonable cause.
Tax penalties exist to encourage compliance, not to serve as a tax in themselves. If you have been assessed penalties for late filing or late payment, we pursue administrative relief through First-Time Abatement (FTA) or by establishing 'Reasonable Cause' under IRC § 6664.
If an agreement cannot be reached at the Examination level, we take the case to the IRS Office of Appeals: a formal protest letter, then representation in administrative conferences. This resolves disputes without the cost and public record of Tax Court litigation, and in Appeals we argue the 'hazards of litigation' to reach a settlement.
Defense protocols: IRC § 6662 accuracy-related penalty defense, Form 843 penalty abatement requests, and 30-day/90-day letter protest filings.
Facing an IRS examination or notice?
Don't respond to the IRS without technical counsel. Our representation practice protects your money and your rights.
Specific deliverables, precisely documented.
“Every response to the IRS is a legal position. We make sure yours are defensible and documented.”
Technical clarifications.
Answers to the most frequently asked questions about how this service works in practice.
No. With a Form 2848 Power of Attorney, we act as your primary representative. In most cases, you never have to speak with an IRS agent or attend a field meeting. We manage all interaction from our office.
An IDR is the formal mechanism the IRS uses to request source documents. Our process involves reviewing every IDR to ensure it is reasonable in scope, then compiling a structured response that provides only what is necessary to support the position.
Yes. We pull your transcripts from the IRS, reconstruct your records, and file current and past-due returns to bring your account into good standing before an audit or collection action begins.
The IRS may waive penalties if you can show you acted in good faith despite being unable to comply due to circumstances beyond your control, such as serious illness, casualty, or reliance on incorrect advice. We document these facts into a formal petition.
A simple office audit might resolve in 3 to 6 months. A complex field audit for a business or family office can take 12 to 24 months. We keep the process moving by responding quickly and submitting organized files.
Related services.
Two Tax Systems, One Team
Email Us
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United Kingdom
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