When possible, assign your worrying to a professional.
The reality:
For many, tax compliance is burdensome and time consuming enough, without examinations or disputes. But, as we all know, sometimes prior returns or positions fall under heightened scrutiny. An audited taxpayer may panic when learning that significant liability—perhaps not previously recognized or planned for—could materialize. Depending on the facts, penalty implications alone can be overwhelming. Not to mention, an unnerved taxpayer may suddenly panic and question the sufficiency of records supporting various positions. Worse, the taxpayer may go down unproductive rabbit holes, diverting (finite) energy to trivial issues or needlessly taking personal offense, all while failing to prioritize exam-inquiry responses. Resource management can be critical to a taxpayer's success on audit. Failing to “triage” areas of taxpayer exposure and formulate a comprehensive strategy can easily become the greatest unforced error.
This firm believes that many taxpayers, particularly small businesses, routinely fail in their evaluation (if any) of uncertain tax positions, whether for financial reporting purposes or otherwise. Inevitably, they discount or even ignore tax-deficiency risks, individually and/or cumulatively. As a result, they're vulnerable and easily caught off guard on examination.
Even so, it's possible things aren't as bleak as they seem. For instance, not all uncertain tax positions will be losers. Also, audit techniques employed by examiners can be intimidating, but they may allow for more flexibility than taxpayers realize. And as a practical matter, some situations are good candidates for settlement offers and negotiations. Taxpayers should not reflexively assume the worst at the outset.
The response:
This firm aims to meet the complex demands of examinations and disputes. It employs a mix of analytical frameworks and tools, rooted in legal and accounting experience (as most suitable for each client), in seeking the most favorable outcome possible under the circumstances.
The firm, managed by Trey M. Bruce, Esq., CPA, LL.M., CFE, believes clients in these situations share certain fundamental criteria for their professional-service needs:
Shared Criteria #1
The professional should remain focused and informed, leveraging all available resources to execute the most advantageous strategy and seek the client's best manageable result.
Response
This firm seeks to bolster clients' protection and security, when responding to IRS scrutiny and otherwise, by drawing on diverse experience, including from legal, accounting, and antifraud engagements.
On audit, the firm has researched and prepared legal and factual arguments to persuade the IRS on material issues. It has dealt with demanding evidentiary obstacles calling for carefully designed responses. In this regard, for intensive examination-request items, the firm has leveraged knowledge of IRM guidelines, identified patterns and developed arguments from circumstantial evidence, and collected and reformatted data to present and support taxpayer-friendly inferences. Ultimately, the firm tries to think outside the box and act resourcefully in tax engagements—and avoid being pigeonholed into one-size-fits-all assumptions.
Shared Criteria #2
When a client needs to speak with a key professional, such professional should make him/herself directly accessible, in a reasonable period of time, for response and dialogue. (This does not include responding 10 days later by delegating a "call back" to an overstretched associate or secretary.) And, naturally, to sustain engagement focus and continuity, key professionals should not seemingly change every day or week.
Response
On core engagement matters, clients generally work exclusively with the firm's Manager, who aims to make himself as directly accessible as possible to clients. Under its BUSINESS approach, the firm works relentlessly to advance client objectives as cost effectively as possible. The firm strives to only accept engagements if it can honor these guidelines.
Shared Criteria #3
Generally, in dealing with taxing authorities, the professional should aim to advance client objectives through well-reasoned analysis, of both substantive and procedural issues, along with individualized strategy. Not through ad hoc posturing or careless short-term tactics.
Response
This firm prioritizes research—perhaps as much as any firm function—and it believes its tax and non-tax work generally reflects that. But if, for whatever reason, the firm does not believe it can meet the research and preparation standards for what it would expect as a client (whether based on firm capacity, engagement-specific criteria, or otherwise), the firm strives to communicate this early and to refer the client elsewhere. The firm recognizes that time is precious, and it doesn't like to waste time of clients or of the firm itself.
In committing itself to these criteria, and in applying its BUSINESS approach more generally, the firm may undertake engagements in the below matters, among others:
- Audits of entities and individuals: IRS, Florida Department of Revenue, Comptroller of Maryland
- Appeals, ADR and/or other dispute resolution
- Bank Secrecy Act and Code section 6050I examinations
- Trust Fund Recovery Penalty disputes
- Innocent spouse and related options for relief
- Third-party liability matters
- International reporting compliance
- Form 8275 positions and related preparation, tax opinions, etc.
- Domestic and international planning: multi-step and integrated transactions, alternatives, etc.
- Internal controls over tax processes and related compliance objectives
The firm strives to perform tax matters cost efficiently and with minimal “drama.” If you believe your situation is a good fit for this firm and its approach, contact Trey to inquire regarding possibilities to work directly with him. If hired, this firm will continually strive to maintain your trust. Regardless, though, the firm wishes you the best.
