Technical topics regarding tax preparation.
3-Aug-2020 2:02pm
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I have a client who needs IRS audit representation in Southern California. Can someone please recommend a good tax attorney. Please PM me.
Thanks
4-Aug-2020 10:42am
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Why do you need an attorney on an examination matter?
Steve Kassel, EA
4-Aug-2020 5:31pm
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Yes it is an examination matter.
4-Aug-2020 10:15pm
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But the question was why do you need an attorney on an examination matter.
5-Aug-2020 7:40am
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Attorney is a good idea if there is a possibility of Fraud.
5-Aug-2020 2:31pm
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rwagner39+ wrote:Attorney is a good idea if there is a possibility of Fraud.
Yes, if there is any substantial possibility that the exam could involve criminal matters, any prior or current communications between the non-attorney practitioner and the taxpayer would not be protected by the attorney-client privilege or the section 7525 privilege with respect to the federally authorized tax practitioner (FATP). The protection also would not be available concerning a communication between the taxpayer and the FATP with respect to certain tax shelters as defined in section 6662(d)(2)(C)(ii), even where no crime was involved.
5-Aug-2020 3:44pm
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An attorney is a good idea if the issue involved has been designated for litigation or has a high probability of litigation. Or if the tax preparer is too busy, especially since there is less risk of losing a return prep client to an attorney than to an EA or CPA. Or the OP may even be concerned that there is a conflict of interest.
-Brian
Director of Tax Accounting Methods & Credits
SourceAdvisors.com
Opinions my own.
5-Aug-2020 10:12pm
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taxnexus wrote:I have a client who needs IRS audit representation in Southern California.
Based on the facts provided, an EA (enrolled agent) should have no trouble representing your client.
6-Aug-2020 7:04pm
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So everyone is curious as to the details about why the O.P. needs a tax attorney, but nobody knows one? Apologies to taxnexus, I don't know any either, well not in California. It appears there is no help to be had hereabouts.
Mostly just commenting to push the post up on the list to improve the odds that somebody who is actually able to be helpful will see it.
Because on T.A. ten was the most you were allowed
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