Taxpayer representation
Every tax notice carries a clock.
Federal and state. Some are automated notices answerable in a letter, some are examinations, and some are the last step before a levy. The first job is telling them apart, because each carries a different deadline. The second is that you should not be the one on the phone in any of those cases.
What the notice actually is
Some people arrive assuming the worst about a routine notice. Others arrive with a genuine examination and have been told it is routine. Both are expensive misreadings.
An automated underreporter notice (a CP2000) means a payer reported income that does not appear on your return. It is a proposal, not a determination, and it is frequently wrong: brokerages report gross proceeds without basis, so a $400,000 stock sale can look like $400,000 of income when the actual gain was a fraction of that. These are answerable with a letter and a schedule.
A CP14 is a balance-due notice and the start of the collection sequence. A Final Notice of Intent to Levy is the end of it, and it carries a 30-day window to request a Collection Due Process hearing, a right that disappears when the window closes.
An examination is a different exercise altogether. A correspondence audit is run by mail and usually confined to one or two line items. An office or field examination means a revenue agent, an information document request, and a scope that can widen if the answers invite it. Here the work is as much about controlling what is produced and when as it is about the substance, and an unfavorable result is not the end. Appeals is a separate forum with a different standard, and it is frequently where these cases are actually resolved.
State agencies are not the IRS
Different sequence, different deadlines, different appeal forum, and a different power of attorney. Treating a state notice like a federal one is how people miss things.
State revenue departments run their own assessment and collection tracks, and several of them move faster and less forgivingly than the IRS does. Response windows are often shorter. The federal first-time abatement has no universal state equivalent, so a penalty that would be waived almost automatically on the federal side may have to be argued from reasonable cause at the state level, or may not be waivable at all.
Residency audits
If you left a high-tax state, this is the examination most likely to find you, and it works differently from an income audit.
Two separate tests
Domicile asks where your permanent home is, and turns on facts a state will argue over for years. Statutory residence is mechanical: a permanent place of abode plus more than 183 days in the state makes you a resident regardless of where you consider home to be. People who satisfy themselves on the first test lose on the second.
New York in particular
New York audits departing residents more aggressively than any other state, and keeping an apartment in the city while spending time there is the fact pattern that triggers it. The evidence is granular: day counts, phone records, credit card activity, E-ZPass.
Where it overlaps with a move abroad
Leaving for Puerto Rico or for another country does not by itself end a state residency claim. The federal treatment and the state treatment are decided under different rules, and it is entirely possible to be right federally and exposed at the state level.
What actually helps
Contemporaneous records, decided before the audit rather than reconstructed during it. Where the move is recent or planned, this is planning work rather than representation, and it is far cheaper in that order.
What representation actually involves
Four things, in this order.
Authority and transcripts
A Form 2848 puts us on the file and takes you off the phone. The first substantive step is pulling account and wage transcripts, because the IRS record and your recollection frequently differ, and the record is what the case is argued from.
The substantive response
Agreeing what is correct, contesting what is not, and documenting it. Where a proposed adjustment is right, conceding it early limits interest. Where it is wrong, it is answered with schedules rather than assertions.
Penalties
First-time abatement where the compliance history supports it, which is close to automatic when you qualify. Reasonable cause where it does not, which has to be built from facts. We will tell you which applies before you engage us.
Paying what is genuinely owed
Streamlined installment agreements below the published balance thresholds require no financial disclosure. Above them, and for an offer in compromise, the IRS wants a full financial picture, and that changes what you should file and when.
A word about the tax relief industry
This is the one area of tax practice with a genuine predator problem, and it is worth naming.
Firms advertising to settle tax debt “for pennies on the dollar” are describing an offer in compromise. It is a real program and it helps people who genuinely cannot pay. But it is arithmetic, not advocacy: the IRS computes what it could reasonably collect from your income and assets over the remaining collection period, and if that figure exceeds what you owe, the offer is rejected no matter who filed it.
What that means in practice is that the outcome is largely determined before anyone is hired. A firm that takes a substantial fee to file an offer it can already see will fail has sold you the filing, not the result.
Common questions
I am actually under examination. Is that different?
Yes, materially. A correspondence audit is usually one or two line items and is answerable by mail. An office or field examination means a revenue agent, information document requests, and a scope that can widen depending on what the answers open up. The work is as much about sequencing and scope control as it is about the substance, and if the result is wrong, Appeals is a separate forum with a different standard, and it is where many of these are actually resolved.
I got a state notice, not a federal one. Same thing?
No, and the differences matter. State revenue departments run their own assessment and collection sequences with their own deadlines, their own appeal forums, and their own power of attorney forms. A Form 2848 does not authorize us with a state. Response windows are frequently shorter, and the federal first-time abatement has no universal state equivalent. There is also a sequencing point: states receive federal adjustment data, so a federal examination that goes against you often produces a state assessment months later. Where both are live they should be run together.
Is a CP2000 an audit?
No. A CP2000 is generated automatically when the income reported on your return does not match what a payer reported to the IRS: a 1099 you did not receive, a brokerage sale reported without basis, a K-1 that arrived late. It proposes a change and invites you to disagree. Treating it as an audit causes people to concede adjustments they should contest; ignoring it causes the proposal to become an assessment.
I got a letter with a deadline. How urgent is it really?
It depends entirely on which letter. A CP14 balance-due notice can wait a short while. A Final Notice of Intent to Levy carries a 30-day window to request a Collection Due Process hearing, and letting that window close gives up rights you cannot get back. The first thing we do is identify the notice and the clock attached to it.
Can you get my penalties removed?
Sometimes, and by two specific routes rather than by asking nicely. First-time abatement is available where the prior compliance history is clean and current filings are up to date, and it is close to automatic when you qualify. Reasonable cause is a facts-and-circumstances argument and has to be built from evidence. We will tell you which, if either, applies before you pay us to try.
Can you settle my debt for a fraction of what I owe?
Rarely, and be careful of anyone who promises it. An offer in compromise is a formula, not a negotiation. The IRS calculates what it could reasonably collect from your income and assets, and if that figure exceeds the debt, the offer is rejected. It genuinely helps people who cannot pay. If you can pay, you will pay, and a firm that told you otherwise took a fee to find that out.
Do I have to talk to the IRS myself?
No. A Form 2848 power of attorney lets us speak and act for you, and correspondence can be directed to us. Where you only need us to see the file rather than act on it, a Form 8821 authorization is narrower and often sufficient. We will tell you which one the situation actually calls for.
How long can the IRS come after me?
Generally three years from filing to assess additional tax, and ten years from assessment to collect it. Both have exceptions that extend them (substantial omissions of income, unfiled returns, certain international forms), and an unfiled return never starts the clock at all. Where the statute has nearly run, that fact changes the strategy.
Book a call about the notice
Thirty minutes, no charge. Have the notice in front of you. The number in the top right corner tells us most of what we need to know.