UNFILED RETURNS
The most common reason returns go unfiled is not evasion. It is that one year was missed, the next was harder, and the gap became its own obstacle.
The relevant fact is procedural rather than moral: options are widest before the Service makes contact, and they narrow at each step after.
Unfiled years are a problem with a shrinking menu.
Every option you have narrows the moment the Service makes contact. Before that, the choice is still yours.
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.
Every step to the right removes an option that existed at the step before it.
SUBSTITUTE RETURNS
Where a taxpayer does not file, the Service may prepare a substitute return from third-party information. A substitute return allows no itemized deductions, no basis in reported sales proceeds, and no filing status better than the least favorable available. The resulting liability is routinely far larger than the correct one. That assessment is frequently reducible by filing a correct return, but the procedure for doing so depends on how far collection has already advanced.
WHY COUNSEL FIRST
Communications with an attorney are privileged. Communications with a return preparer are not, in any respect that matters if the exposure turns out to be criminal. Where the facts are unexamined — and by definition they are, in a multi-year non-filing situation — the assessment should happen inside the privilege. Where return preparation is then required, the firm can prepare and sign the returns, or engage the accounting work under a Kovel arrangement so it remains privileged.
WHAT THE FIRM DOES
Fixes the actual scope
how many years must be filed, which is frequently fewer than the taxpayer assumes.
Pulls the Service’s own transcripts
and reads them before anything is prepared or filed.
Tests for criminal exposure
under privilege, before any voluntary contact is made.
Prepares and files the returns
signed by the attorney who reviewed the exposure.
Addresses penalties, and moves the resulting balance into the appropriate collection alternative
Options are widest before the Service makes contact, and they narrow at every step after.
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.
The assessment happens under privilege, before anything is filed. Contact the firm through the contact page or call (561) 529-5873. Representative engagements are described on the Experience page.