Tax Controversy Representation

Our subscription-based model provides ongoing access to sophisticated tax guidance without surprise billing: Included Services: • Unlimited tax questions via email and scheduled calls • Transaction review and structuring guidance • Tax position documentation and support • Planning strategy consultation • Legislative update briefings Priority Response: Subscription clients receive priority response times for urgent matters, ensuring critical decisions aren't delayed waiting for professional guidance. Proactive Engagement: Beyond reactive questions, we proactively identify planning opportunities based on changes in your situation, tax law, or regulatory environment. Cost Certainty: Fixed monthly fees allow accurate budgeting while encouraging clients to seek guidance early—when planning is most effective—rather than delaying due to fee concerns. Scope of Consulting: Our tax consulting covers federal, state, and international tax matters for individuals, businesses, trusts, and estates. Complex transactions may require supplemental engagement letters for defined scope work.

Representation before the IRS under Treasury Circular 230, including examinations, appeals, and collection matters. Not legal representation. Matters requiring an attorney are referred to outside counsel.

Trusts are powerful tools for asset protection, tax planning, and wealth transfer. We provide comprehensive trust services: Trust Formation: • Revocable Living Trusts — Avoid probate, maintain control • Irrevocable Life Insurance Trusts (ILITs) — Remove insurance from estate • Grantor Retained Annuity Trusts (GRATs) — Transfer appreciation tax-efficiently • Qualified Personal Residence Trusts (QPRTs) — Discounted home transfers • Charitable Trusts (CRTs, CLTs) — Charitable giving with income stream • Intentionally Defective Grantor Trusts (IDGTs) — Freeze estate while paying taxes Trust Administration: • Fiduciary accounting and reporting • Trust tax return preparation (Form 1041) • Distribution planning and documentation • Trustee guidance and support • Beneficiary communication Trust Modifications: • Trust decanting where state law permits • Non-judicial settlement agreements • Court-approved modifications • Trust termination procedures We work with estate planning attorneys to ensure trusts are properly drafted and with fiduciaries to ensure proper administration.

When the IRS or state tax authority challenges your position, experienced guidance is essential: Pre-Controversy Planning: • Audit-proofing documentation • Position substantiation • Disclosure strategy • Statute of limitations management Examination Phase: • Information document request (IDR) response • Examiner meeting preparation and representation • Position papers and technical memoranda • Closing agreement negotiation Administrative Appeals: • Protest preparation • Appeals conference representation • Settlement negotiation • Fast Track Settlement (FTS) procedures • Post-Appeals Mediation (PAM) Penalty Defense: • Reasonable cause documentation • Good faith defense preparation • Reasonable basis analysis • Substantial authority positions • Adequate disclosure strategies Our approach combines technical expertise with practical experience in how tax authorities actually operate—enabling more efficient and favorable resolutions.

Most taxpayer interactions with the IRS begin with correspondence. We handle all IRS communications to ensure proper responses and protect your rights: Notice Response: • CP2000 — Underreporter notices • CP14 — Balance due notices • CP501-504 — Collection notices • LT11 — Final notice of intent to levy • Letter 525 — Examination report • Letter 950 — 30-day letter Response Preparation: • Deadline tracking and management • Documentation gathering and organization • Technical response drafting • Supporting evidence compilation • Follow-up and resolution tracking Transcript Analysis: • Wage and Income Transcript review • Account Transcript interpretation • Return Transcript verification • Record of Account analysis Power of Attorney: We file Form 2848 to represent you before the IRS, ensuring all communications come through our office rather than directly to you.

Transfer tax planning requires integration of legal, tax, and financial considerations. Our services include: Gift Tax Planning: • Annual exclusion optimization • Lifetime exemption utilization strategy • Gift splitting elections • Form 709 preparation and filing • Adequate disclosure for statute purposes Estate Tax Planning: • Portability election planning • Estate tax return preparation (Form 706) • Valuation discount documentation • Asset protection integration • Generation-skipping tax planning Post-Death Administration: • Fiduciary income tax returns • Estate administration guidance • Distribution planning • Section 645 elections • Basis step-up documentation Audit Defense: • Estate and gift tax audit representation • Valuation defense • Discount substantiation • Technical position support

Understanding the scope of our services ensures appropriate expectations and proper engagement: Services Included: • Tax-related legal consultation • Administrative tax controversy representation • Trust formation and administration guidance • Tax return preparation and filing • Tax planning and strategy • IRS and state correspondence handling Services Requiring Referral: • Tax Court litigation (we can refer to specialized counsel) • Non-tax legal matters • Criminal tax investigations • Complex securities law matters • Patent and intellectual property • Employment law disputes Collaboration Model: For matters outside our scope, we maintain referral relationships with specialized attorneys and coordinate to ensure seamless client service. We can continue providing tax guidance while litigation counsel handles courtroom matters. Conflicts & Independence: We maintain independence standards appropriate to our services and will identify potential conflicts before engagement.