Art Bradham CPA PC
IRS Examinations & Appeals
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The best solutions to most tax examinations
occur at the agent level. If it is possible to
resolve a case at that level, usually that’s the
least expensive, both in terms of tax to be paid
and representation fees. If possible, I love to
have an opportunity to be involved in an
examination before everyone has “drawn a line
in the sand” or at least before the final report
has been written. No one likes to be shown up,
and agents are people too. If it is possible to
present documentation or authority that the
agent can accept, that is the place to do it.
Unfortunately, I rarely get involved with a
practitioner referred case until late in the
process. That doesn't mean nothing can be
done. To the contrary, sometimes the best
approach is a new one. That’s why the IRS
uses an appeals officer who has no previous
contact with the case. By entering the case after
the battle lines have been drawn, I have the
distinct advantage of not being limited to a
previous position. My approach is fresh, and
sometimes a different approach yields results. I
am very pragmatic in IRS examinations; I will
concede minor issues if I think the major issues
can be won as a result.
As a practitioner, what happens when you have
gone as far as you can with the Examination
Division? Appeals? Tax Court? Capitulation? I
can provide valuable assistance in evaluating
possible courses of action, considering the
possible costs and contingencies of each avenue.
occur at the agent level. If it is possible to
resolve a case at that level, usually that’s the
least expensive, both in terms of tax to be paid
and representation fees. If possible, I love to
have an opportunity to be involved in an
examination before everyone has “drawn a line
in the sand” or at least before the final report
has been written. No one likes to be shown up,
and agents are people too. If it is possible to
present documentation or authority that the
agent can accept, that is the place to do it.
Unfortunately, I rarely get involved with a
practitioner referred case until late in the
process. That doesn't mean nothing can be
done. To the contrary, sometimes the best
approach is a new one. That’s why the IRS
uses an appeals officer who has no previous
contact with the case. By entering the case after
the battle lines have been drawn, I have the
distinct advantage of not being limited to a
previous position. My approach is fresh, and
sometimes a different approach yields results. I
am very pragmatic in IRS examinations; I will
concede minor issues if I think the major issues
can be won as a result.
As a practitioner, what happens when you have
gone as far as you can with the Examination
Division? Appeals? Tax Court? Capitulation? I
can provide valuable assistance in evaluating
possible courses of action, considering the
possible costs and contingencies of each avenue.
| Call us: 803-774-1040 Email us: art@artbradham.com |