AUDIT RECONSIDERATION
An adjustment that has been assessed is not always final. Three routes reopen a liability that was decided without the taxpayer’s full participation, or without the taxpayer at all.
Assessed without ever telling your side?
An assessment built on records you never presented can often be reopened. It does not always stay final.
Scheduling does not create an attorney-client relationship. No such relationship exists until the firm has run a conflicts check and both sides have signed a written engagement agreement.
AUDIT RECONSIDERATION
Where an assessment was made on information the taxpayer never presented — a default, an unopened notice, an examination conducted without records that existed — the Service can be asked to reconsider. There is no statutory deadline, but the request must present what the examination did not have, and the collection clock keeps running while it is pending.
INNOCENT SPOUSE RELIEF
A joint return creates joint and several liability. Where one spouse bore no responsibility for an understatement and, on the facts, should not bear the liability, relief is available under section 6015 in three distinct forms with different requirements and different deadlines. These matters are fact-intensive and frequently turn on what the requesting spouse knew or had reason to know. They are also reviewable in the United States Tax Court.
DOUBT-AS-TO-LIABILITY OFFERS
An offer in compromise is usually understood as a collection remedy. A separate form exists where the dispute is over whether the tax is owed at all, rather than whether it can be paid. It is the correct tool in a narrow set of cases and the wrong one in most.
The detailed procedure is set out in Exam Alternatives.
An assessment made without the taxpayer is not always the end of the matter.
HOW AN ENGAGEMENT BEGINS
Book a free consultation
Thirty minutes, no charge. Bring the notice — we read it together on that call.
The deadline is identified
Which notice it is, what it asserts, and which forums are still open behind it.
Conflicts check and written engagement
Scope and fee agreed in writing before any work begins.
HOW A CONTROVERSY RESOLVES
The firm takes over
Correspondence with the Service runs through the firm. You stop answering.
The position is built and pressed
Records, authority, and the argument — pressed at the earliest stage that will take it, because that is the cheapest place to win.
Resolution
Closed at examination, settled at Appeals on the hazards, or tried. The firm does not hand the file to anyone to reach the last of those.
Whether any of these routes is available turns on how the assessment was made. Contact the firm through the contact page or call (561) 529-5873. Representative engagements are described on the Experience page.