irs tax disputes
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RICHARD CARPENTER
CERTIFIED TAX LAW SPECIALIST
NAMED A 2008 "SUPER LAWYER"
 
WHEN DEALING WITH THE IRS, EXPERIENCE IS CRITICAL
AND RESULTS ARE WHAT COUNT
... THAT'S THE BOTTOM LINE.

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.

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 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 a taxpayer never has 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.
  • 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 24+ 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).

     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 24+ 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 24+ 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 some glitzy looking "tax-help" website. 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 worst yet only a para-legal or an 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 ...  Many tax attorneys and CPA's look to San Diego Tax Attorney Richard Carpenter for expert guidance in helping their clients resolve serious tax problems with the IRS.

WHEN THE IRS COMES CALLING ...

  When the IRS comes calling, and you know that you are really in trouble, place your tax problems in the hands of San Diego tax attorney RICHARD CARPENTER. Please call me at (619) 696-8607 to discuss your tax situation in complete confidence. I can help you.

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RICHARD CARPENTER
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.
credit cards accepted
 
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irs audits
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-  Free initial consultation
-  Certified Tax Law Specialist
-  24+ years tax law
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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
-Top 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
CALL   (619) 696-8607
San Diego Tax Law Offices
of Richard Carpenter
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Terms of Use     4/05/05 Privacy Policy

© 2006-2008 RICHARD CARPENTER, ATTORNEY AT LAW.    ALL RIGHTS RESERVED.
Written by Richard Carpenter. Illustrations selected by Richard Carpenter.
Attorney Website Design by LawMarkets.com

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