Brennan and Company CPA, PC of Philadelphia provides consulting services that include client tax representation services. In-order to represent clients before the IRS the practitioner must be actively “practicing”. To be considered “practicing” before the IRS, Circular 230 states that the Practitioner must be one from a group of specifically licensed professionals such as CPA’s and Attorney’s. While a person may represent themselves before the IRS, any practitioner or tax preparer cannot necessarily represent a client in resolving tax disputes with IRS.
Tax Representation Service is a highly specialized consulting service and one that we have offered…successfully for years at Brennan and Company CPA, PC. Our first tax representation case was a 1998 OIC case (Offer-in-Compromise) which we won. We have since handled other successful tax representation cases.
You may have seen those late night television advertisements where the latest “tax specialist” sits ready to resolve your tax debt for “pennies” on the dollar….”all you have to do is call!” These ads can infer that an OIC (Offer-in-Compromise) may be easily obtained from the IRS. This is another example of an advertising pitch for when it sounds too good to be true, it is often too good to be true!
The IRS acceptance rate for a negotiated settlement of tax debts is historically lower than 35% out of 100.
This is not to say you won’t ever qualify for a negotiated tax settlement. This is not a reason you should avoid a negotiated tax debt settlement. However, the likelihood of obtaining a negotiated settlement of your tax debt is never guaranteed.
Furthermore OIC settlement mills often require an upfront fee AND a monthly installment agreement to pay off your consulting fee — regardless of your outcome. Brennan and Company has turned away more OIC clients (and the potential for up front retainers) than we have accepted over the years because many clients do not qualify.
When we do accept an OIC or representation case we work the case because a compelling reason exists. We then work according to an agreed upon fee structure with all terms highlighted in a plain language engagement letter. Once retained, we fight to obtain the best possible settlement.
An OIC settlement may be feasible in one case and in another case a manageable installment payment agreement may be the best deal. Other outcomes are possible and other IRS settlement agreements exist.
Many factors can affect case outcomes including the availability of the client records, the amount of the tax debt, the ability to liquidate assets to pay debts and the statute of limitations remaining for IRS collection efforts.
Brennan and Company represented a client in 2003 with a seemingly intractable tax dispute that dragged on for many years. It was determined that the IRS collection statute of limitations had expired. The IRS had no choice but to accept a $0 balance due offer. We saved the client well in excess of $100,000.
This outcome is not typical but it demonstrates that different strategies exist and, with our applied expertise, we may be able to resolve your difficult tax dispute.
We also represent clients during an IRS audit and appeal actions. We can assist in local and state tax collection disputes.