irs tax disputes
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RICHARD CARPENTER
TAX ATTORNEY AND LAW PROFESSOR
CERTIFIED TAX LAW SPECIALIST
NAMED A "SUPER LAWYER" IN 2008, 2009 AND 2010
 
WHEN DEALING WITH THE IRS, EXPERIENCE IS CRITICAL.
  PUT MY 26 YEARS OF TAX LAW EXPERIENCE
TO WORK FOR YOU.

IRS AUDITS

During the past year, the IRS audited nearly 2 million tax returns and recommended over 28 BILLION dollars in additional tax and penalties. Beware of the hidden dangers in an IRS audit. It is not a "neutral" proceeding. The IRS tries to use the audit interview process to obtain damaging admissions from a taxpayer, and/or the taxpayer's audit representative, so that the IRS can assert penalties at the audit's conclusion.

Because a complete understanding of IRS Regulations, and the ability to timely assert various legal defenses can limit or prevent inappropriate proposed audit assessments, the intervention of a skilled tax professional, experienced in IRS tax disputes, is crucial at the audit stage. If you are facing an IRS audit, San Diego tax attorney Richard Carpenter can help you. Put my 26 years of tax law experience to work for you.

DID YOU KNOW THAT ...

  • The IRS uses a Discriminant Function System to grade tax returns and the higher the score, the greater the audit chance.
  • Self-employed taxpayers also have a substantially higher chance of audit.
  • The IRS has a special criminal tax task force assigned to track down those Americans with offshore bank accounts and offshore credit cards who have failed to report them.
  • The IRS generally has only a 3-year time period to make changes to a tax return already filed.
  • Under certain circumstances, the IRS tries to extend the statute of limitations period from 3 years to 6 years.
  • The IRS sometimes uses "indirect methods" of proving that a taxpayer has unreported income.
  • Negotiation skills play an important part in obtaining the best possible audit results.
  • There is a wonderful audit technique called the "Cohan rule".
  • Every taxpayer has the right to appeal their IRS audit findings.

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

  • Communicating directly with the IRS, so that you never have to meet with them.
  • Carefully reviewing the tax return to spot possible "trouble" areas before the audit begins.
  • Performing any necessary research to strengthen a taxpayer's position.
  • Planning an effective overall audit strategy.
  • Presenting the taxpayer's position in the most favorable light possible.
  • Preventing an offshore bank account / offshore credit card tax matter from escalating into a criminal tax case.
  • Having the audit at my office to avoid any disruption to a taxpayer's business and embarrassment in front of employees and customers.
  • Challenging any IRS attempt to extend the statute of limitations period to 6 years.
  • Challenging any IRS attempt to "indirectly" prove unreported income.
  • Utilizing my negotiating skills to resolve as many audit issues as 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. While the facts and circumstances of every IRS tax audit vary, for 26 years I have been able to utilize certain proven techniques to obtain the best possible audit results for my clients.

     I am a part-time tax law professor, a Certified Tax Law Specialist, and the author of 14 published articles, one of which is a leading article concerning IRS audits ("FOREWARNED IS FOREARMED AT IRS AUDIT", published in Taxation For Accountants, March 1998).

I have been recognized as one of the Top San Diego County Attorneys in 2007, 2009 and 2010 by the San Diego Daily Transcript legal newspaper and was also named a "Super Lawyer" in 2008, 2009 and 2010.

     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 26 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 26 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.

EXPERT GUIDANCE ... During the past 26 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 ...

I understand how a tax problem can take hold of your life and affect your ability to sleep at night. 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 26 years of tax law experience to work for you. Hire A "Super Lawyer" To Resolve Your Tax Problems.

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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
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I accept all major credit cards.
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irs audits

RICHARD CARPENTER

______________
SAN DIEGO TAX ATTORNEY
-  Certified Tax Law Specialist
-  26 years tax law
-
experience
-  Law practice limited to
-resolving tax disputes,
-civil and criminal
-  Skilled negotiator, well
-respected, fights for best
-results
-  Daily successes in resolving
-all tax disputes
-  Tax law professor
-  Named one of San Diego's
-Best Tax Attorneys
-  Able to communicate
-directly with IRS or
-California on your behalf
-  Educated in tax law: 
- •  Juris Doctorate
- •  Masters in Taxation
- •  B.B.A. in Accounting
- •  CPA training &
-      experience
-  Reasonable fees, all major
-credit cards accepted
-  Prompt, confidential help
-  Dedicated to defending honest
-taxpayers against the far and
-powerful reaches of the
-Internal Revenue Service
I CAN HELP YOU.
. . .
PUT MY 26 years OF TAX LAW EXPERIENCE TO WORK FOR YOU.
. . .
CALL   (619) 696-8607
Richard Carpenter
San Diego Tax Lawyer
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© 2006-2009 RICHARD CARPENTER, ATTORNEY AT LAW.    ALL RIGHTS RESERVED.
Written by Richard Carpenter. Illustrations selected by Richard Carpenter.
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