IRS Controversy
Past the exam basics: information document requests and summonses, collection due process, liens and levies, offers in compromise, trust fund penalties, privilege, and the Taxpayer Advocate — the procedural terrain where specialty claims are defended.
Start here
4 piecesNo background assumed — the pieces that build the foundation.
Guide · Intro · 7 min
IRS collection defense: the notice stream, liens, levies, and your exits
How the IRS collection machine works from the first CP14 balance-due notice to levy, and the defensive tools available: CDP hearings, installment agreements, currently-not-collectible status, offers in compromise, and the 10-year collection statute.
Brief · Intro · 3 min
Federal tax liens: how the NFTL works and how to get out from under it
A federal tax lien arises automatically when assessed tax goes unpaid and attaches to everything you own; the Notice of Federal Tax Lien makes it public and establishes priority. Withdrawal, discharge, and subordination — and an honest word on credit impact.
Brief · Intro · 3 min
Offers in compromise: the math the ads leave out
An offer in compromise settles tax debt for the taxpayer's reasonable collection potential — equity in assets plus a multiple of monthly disposable income — not for 'pennies on the dollar.' How RCP works, doubt-as-to-collectibility versus liability, and real acceptance odds.
Brief · Intro · 3 min
The Taxpayer Advocate Service: what it fixes and what it can't
TAS is an independent organization inside the IRS that intervenes when normal channels have failed and the taxpayer faces hardship or systemic delay. When Form 911 works, how Taxpayer Assistance Orders operate, and the limits the ads never mention.
The working layer
5 piecesThe practitioner's day-to-day rules, mechanics, and traps.
Guide · Working · 9 min
IDR strategy: managing the information flow in an IRS exam
How to scope, negotiate, and respond to Information Document Requests — including the delinquency-to-summons escalation path, privilege screens before production, and the IDR patterns specific to R&D credit and cost segregation exams.
Brief · Working · 4 min
Voluntary disclosure options: fixing past noncompliance before the IRS finds it
The menu for correcting old tax problems — qualified amended returns, the IRS Voluntary Disclosure Practice for willful conduct, streamlined-style relief for non-willful foreign issues — and why 'quiet disclosure' is usually the worst of the available choices.
Brief · Working · 4 min
The trust fund recovery penalty: when payroll tax debt becomes personal
Section 6672 lets the IRS assess a company's unpaid withheld payroll taxes against any 'responsible person' who 'willfully' failed to pay them over — owners, CFOs, sometimes bookkeepers. How the two elements work, what the Form 4180 interview is really for, and how to defend.
Brief · Working · 3 min
CDP hearings: what Sections 6320 and 6330 actually preserve
A Collection Due Process hearing, requested within 30 days of a lien filing or final levy notice, suspends most levy action and preserves Tax Court review — the only routine judicial check on IRS collection. Timing rules and raisable issues, explained.
Brief · Working · 4 min
Form 872 statute extensions: when to consent, and on what terms
The IRS routinely asks taxpayers to extend the three-year assessment statute during exams. Consent is voluntary and negotiable — fixed-date versus open-ended Form 872-A, restricted consents limited to specific issues, and the Appeals-access trade-off.
Pro details
3 piecesSpecialist nuance: edge cases, interactions, and planning.
Brief · Pro · 4 min
Privilege in tax matters: §7525, Kovel, and the unprivileged credit study
How attorney-client privilege, the Section 7525 practitioner privilege, and work-product protection actually apply in tax controversies — Kovel arrangements, waiver traps, and why R&D credit and cost segregation workpapers are usually discoverable.
Brief · Pro · 3 min
IRS summons enforcement: Powell, third parties, and John Doe summonses
The Section 7602 summons is the IRS's compulsory process, enforced in district court under the minimal Powell standards. What Powell actually requires, how third-party and John Doe summonses differ, and the narrow real-world grounds for resisting.
Brief · Pro · 3 min
Section 6751(b): the supervisory-approval defense to penalties
No penalty may be assessed unless the initial determination was personally approved in writing by the examiner's immediate supervisor. How the Graev/Chai litigation wave rewrote penalty practice, the timing rules by forum, and how to raise the defense.