IRS APPEALS

While every taxpayer has the right to appeal their audit findings, be advised that the IRS Appeals Officer will be far more experienced and far more knowledgeable than the initial IRS audit Revenue Agent. It is imperative for any taxpayer with an IRS tax dispute heading towards appeals to immediately retain a skilled tax attorney to plan an effective overall appeal strategy. There are some taxpayers who will actually benefit more by not having an IRS Appeals conference. Also, detailed tax research will likely be needed to strengthen a taxpayer's settlement position. If you need to appeal IRS audit findings, or have another type of IRS problem or tax dispute, San Diego tax attorney Richard Carpenter can help you.

DID YOU KNOW THAT ...

• A taxpayer's audit protest must be timely filed for Appeals to have jurisdiction over the case.
• Every Appeals Officer has wide latitude in settlement.
• Negotiation skills play an important part in obtaining the best possible settlement in appeals.
• The appeal steps are different for "non-docketed" cases and "docketed" cases.
• There is a wonderful appeal technique called the "Cohan rule".
• Many IRS penalties can be waived for reasonable cause.
• Most unagreed appeal cases can be taken to Tax Court.

SAN DIEGO TAX LAWYER RICHARD CARPENTER CAN HELP BY ...

• Evaluating a taxpayer's entire case to determine if an appeal is the best option.
• Planning an effective overall appeal strategy.
• Performing all necessary tax research to strengthen a taxpayer's position and prepare for the appeal conference.
• Communicating directly with the IRS Appeals Officer, so that a taxpayer never has to meet with him/her.
• Utilizing my negotiating skills to obtain the best appeal settlement possible.
• Asserting the "Cohan rule" when applicable to estimate allowable deductions when taxpayer records are not available.
• Putting forth appropriate "reasonable cause" exceptions to penalties.

RICHARD CARPENTER'S EXPERIENCE ...

     Since 1984, I have successfully represented more than one thousand clients in resolving their IRS tax disputes. I have the knowledge and 25 years of experience to obtain the best appeals settlement possible.

     I am a part-time tax law professor, a Certified Tax Law Specialist, and the author of 14 published articles, including some of the leading articles resolving IRS tax disputes.

     Unlike some tax controversy defense attorneys, I did not start out my legal career as an IRS attorney using the Tax Code against honest taxpayers. I also did not start out my legal career as a federal prosecutor working to put good people in prison for some mistakes on their tax returns. Instead, I have devoted my entire 25 year legal career helping to defend hardworking, family-oriented taxpayers against the far and powerful reaches of the Internal Revenue Service and I am proud of that accomplishment. Being an effective tax controversy defense attorney is a mindset and I have had that tax defense mindset for my entire 25 year legal career.

WARNING: Tax law is complex. Thus, it is very important that you hire only an experienced, State Bar Certified, tax attorney to represent you and that you carefully review their background before you hire them. I recommend a minimum of 15 years of tax controversy defense experience. Don't be fooled by those "tax-help" company websites. As you may have already noticed, many of those websites intentionally avoid listing the background of the tax person who will be working on your case because he / she is either a novice attorney, or worse yet only an enrolled agent or accountant.

Successfully solving tax law problems requires skill, plus tax law knowledge and years of experience. It is certainly not a job for a novice attorney. To protect yourself, you should hire only a tax attorney who is a Certified Tax Law Specialist by the State Bar. Remember, there is no such thing as a routine call or letter to the IRS. A skilled Certified tax lawyer will tailor each communication precisely to your specific tax defense plan. Each communication to the IRS means something and it is very important that nothing is overlooked or taken for granted.

EXPERT GUIDANCE ... During the past 25 years, many attorneys and CPA's have looked to San Diego Tax Attorney Richard Carpenter for expert guidance in helping their clients resolve serious tax problems with the IRS. For a complete description of my background, please click here.

HELP IS AVAILABLE TO YOU ...

 If you are serious about resolving your tax problem, I can help you. Please call me at (619) 696-8607 to discuss your tax situation in complete confidence. Put my 25 years of tax law experience to work for you.

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RICHARD CARPENTER
SAN DIEGO TAX ATTORNEY
406 Ninth Ave., Suite 213
San Diego, CA 92101
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TELEPHONE: 619/696-8607
FAX: 619/696-0126
E-MAIL: rc4taxlaw@aol.com *
 
I accept all major credit cards.

 
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