The stages the work covers
Tax controversy work usually begins with a notice, whether an audit letter, a proposed adjustment, a balance due, or a collection threat. It can then move through examination, the Independent Office of Appeals, and the courts, or branch into collection matters such as levies, liens, and payment arrangements. State tax departments run parallel processes with their own names and deadlines. A matter can also turn criminal, which changes who should be involved and what should be said. Identifying the current stage is what reveals the deadlines already running and the decisions actually in front of you.
Who can handle which part
Before the IRS, attorneys, certified public accountants, and enrolled agents can generally represent taxpayers under a power of attorney. In Tax Court, attorneys are admitted on application, while non-attorneys must pass the court's own examination. Communications with a lawyer can be privileged, whereas the protection for communications with other tax practitioners is narrower and does not apply in criminal matters. Many cases work well with an accountant handling the numbers and a lawyer handling strategy and legal risk, sometimes under an arrangement that can bring the accountant's work within the lawyer's privilege. Gather your returns, notices, prior correspondence, and any engagement letters with current advisers so the team can be set up properly.
Defining the engagement
At the start we identify the notice that began the matter, the years and taxes involved, and any deadline that is already close. Next we agree on what the work would include, whether that is responding to an audit, preparing a protest, negotiating collection, or preparing for court. Defining the scope early keeps costs more predictable and avoids gaps where nobody is watching a deadline. If your current accountant is staying involved, we discuss how responsibilities will be divided.
