When the notice arrives.

The letter that changes the week.

An IRS notice is never convenient and rarely obvious. A CP2000 claiming additional income. An audit notification for a prior year. A penalty assessment for a form that was filed correctly but matched incorrectly on the IRS side. A state notice about residency. A nexus assertion from a state where you did not think you had a filing requirement.

These are not situations where you want your CPA to panic or hand you off to a specialist they have no real relationship with. They are situations where you want someone who does this work routinely, knows the process, and can speak the IRS's language.

What we take on.

Federal IRS matters. Responses to IRS notices including CP2000, CP2501, notices of deficiency, and notices of intent to levy. Full audit representation for correspondence, office, and field audits. Penalty abatement requests on reasonable cause, first-time abatement, and administrative waiver grounds. Installment agreements for taxpayers with balances they cannot pay in full. Offers in compromise when the facts actually support one (we are honest about when they do and do not). Collection due process hearings. Appeals of audit determinations. Responses to employment tax assessments and trust fund recovery penalty notices.

State controversy. New York State residency audits, which are a specialty given our New York focus. New York State income tax notices and disputes. New York City Department of Finance notices, including GCT and unincorporated business tax matters. Multi-state nexus disputes, including states asserting income tax or sales tax nexus where the taxpayer did not believe nexus existed. State-level penalty assessments and abatement requests. Representation at state-level appeals.

Why this is a real engagement.

Controversy work is not something a firm dabbles in. The IRS has procedures, forms, and expected responses at each stage of a dispute. A weak or late response can turn a small problem into a large one. A well-crafted response at the right stage can make the entire matter disappear.

We do this work regularly enough that we know the rhythm. We know which IRS offices respond quickly and which do not. We know which penalty abatement arguments land and which get rejected. We know when a taxpayer has a strong case and when they have a bad one that needs realistic framing.

What we tell clients honestly.

Some tax controversy situations have better outcomes than others. We will tell you directly what we think your exposure is, what realistic resolution looks like, and whether the juice is worth the squeeze on fighting a particular issue. We have turned down engagements where the client wanted us to fight a losing battle. We have also taken on engagements where the client had been told their situation was hopeless and was not. The work requires honesty in both directions.

When this engagement fits.

• You received an IRS notice and do not understand it or know how to respond
• Your prior firm prepared a return that is now being examined
• You have an outstanding IRS or state balance and need a structured resolution
• You received a New York residency audit letter
• You received a notice from a state where you did not think you had a filing requirement
• Your business is being assessed employment tax penalties
• You need representation at an appeal or collection hearing

Scan the notice. Email it. We will tell you what you are looking at and what the engagement would cost.