04 · IRS Practice & Representation

IRS Representation.

Audit defense, collections resolution, appeals — under unlimited practice rights before the Internal Revenue Service as authorized by 31 U.S.C. §330 and Circular 230.

Key Points

What you need to know about IRS representation.

  • Enrolled Agents hold unlimited practice rights before every IRS office — examinations, collections, and appeals — under 31 U.S.C. §330.
  • Once a Form 2848 Power of Attorney is filed, you do not meet with the IRS — all contact goes through the representative.
  • Most IRS notices require a response within 30–60 days — do not ignore them.
  • First-Time Abatement (FTA) may eliminate certain penalties for taxpayers with a clean compliance history.
  • Offers in Compromise are accepted only when the IRS determines a taxpayer cannot pay the full liability — acceptance rates are low; documentation is critical.
  • Representation fees are billed hourly with a disclosed retainer, in compliance with Circular 230 §10.27.
What's Included

The full scope of work.


Each engagement begins with a written scope and a flat or hourly fee disclosed in advance, in compliance with Circular 230 §10.27.

Audit Defense

Represent you before the IRS in correspondence, office, and field examinations — you don't meet with the IRS.

  • Form 2848 power of attorney
  • Document production and advocacy
  • Revenue agent negotiation
  • 30-day letter response

CP2000 & Notice Response

Under-reporter notices, math-error notices, and correspondence examinations resolved with proper documentation.

  • CP2000 response letters
  • CP2501 and CP3219A defense
  • Math-error reversal
  • Identity verification (5071C)

Installment Agreements

Streamlined, non-streamlined, and partial-pay installment agreements with the IRS.

  • Form 9465 preparation
  • Streamlined (<$50k)
  • Non-streamlined with Form 433-F/A
  • Partial-pay IAs

Penalty Abatement

First-time abatement and reasonable-cause abatement for failure-to-file, failure-to-pay, and accuracy penalties.

  • First-time abatement (FTA)
  • Reasonable-cause statements
  • Form 843 claims
  • Accuracy-related penalty defense

Offers in Compromise

IRS settlement program for taxpayers who cannot pay their full liability — documented and substantiated.

  • Form 656 and Form 433-A (OIC)
  • Reasonable collection potential analysis
  • Doubt as to collectibility
  • Doubt as to liability

Appeals & Collections Due Process

IRS Office of Appeals representation and CDP hearings — independent of the original examiner.

  • Form 12203 appeals request
  • Form 12153 CDP hearing
  • Settlement negotiation
  • Equivalent hearings
Our Process

Four steps, end to end.


The same workflow whether the engagement is a single 1040 or a multi-entity consolidation — predictable, documented, and auditable.

01

Intake & POA

Review the notice, sign Form 2848 Power of Attorney, and pull full IRS transcripts to establish the full picture.

02

Strategy

Identify the best resolution — first-time abatement, installment agreement, OIC, audit reconsideration, or appeal.

03

Execution

Prepare and file the required response, protest, or collection resolution package with full documentation.

04

Resolution

Negotiate with the IRS on your behalf, confirm resolution in writing, and close out the POA when the matter is complete.

Transparent flat-fee or hourly pricing.

Representation work is billed hourly at $250/hour with retainers scoped to the matter. Note on scope: Enrolled Agents represent taxpayers at the IRS administrative level — before the examining agent, the Office of Appeals, and collections. U.S. Tax Court litigation requires an attorney or an EA who has passed the Tax Court examination; we will refer Tax Court petitions out when necessary. See the full public fee schedule for detailed breakdowns and Circular 230 §10.27 compliance notes.

View Fee Schedule Request a Quote

Ready to get started?

Upload your prior return and supporting documents through the secure Client Portal, or schedule a consultation to discuss your matter.