Former Supervisory Manager and tax attorney-Advisor, Internal Revenue Service, Office of Chief Counsel, IRS National Office, Washington, DC - final signature authority for technical advice to District Directors, Letter Rulings, and other IRS interpretative determinations - signature authority on IRS Tax Regulations, Revenue Rulings and other published positions of the IRS .
Our National IRS tax attorney practice specializes in IRS problems and controversies, including: "offers in compromise", IRS tax liens, IRS collection actions including levies, wage garnishments, IRS civil and criminal investigations, installment agreements, penalty abatements, IRS appeals, consultations services, fraudulent transfers, litigation services and other IRS pro-active services.
Using Offer in Compromise services as an example, we have the advantage of having "offer in compromise" cases throughout the U.S. In negotiating offer in compromise settlements, we have a national perspective. We have unique insight into unpublished IRS administrative practices and policies in offer in compromise cases. For these reasons, we are able to settle offer in compromise cases at the lowest amount that the IRS will accept for an "acceptable Offer" (i.e., final settlement). In addition, our insight into IRS administrative practices in offer in compromise cases minimizes the opportunities the IRS has to return an Offer case without resolution. We prepare offer in compromise Form 656 and financial statement Form 433A and Form 433B so that the presentation to the IRS is professional. A tax attorney prepares a legal memorandum in all Offer in Compromise filings, in order to make sure that the IRS is following the IRS statute on §7122 (the OIC statute), the Offer regulations, the legislative history, the tax policy in Offer cases, the Offer case law, and the Revenue Procedure in offer in compromise cases. The task of our tax lawyers in offer in compromise cases is to force the IRS to follow the all of the legal and administrative procedures as well as the Congressional mandate to the IRS to be "liberal" in OIC cases.