Specific Areas of IRS Enforcement

PROMOTER PENALTY EXAMINATIONS

With the creation of the IRS’s Office of Promoter Investigations it has never been more important to have defense counsel who is intimately familiar with how to defend against promoter penalties under IRC § 6700.  Promoter penalties are perhaps the most deadly weapon in the IRS’s civil penalty arsenal.  They are incredibly costly and procedurally difficult to defense because taxpayers are required to pay a portion and file a claim for refund quickly in order to contest the penalty.  We’ve been there before, so we know how to defend against these penalties.

Some of our promoter penalty results include:

• Determination by IRS to end promoter penalty examination without assessing civil penalties.
• Abatement of over $20 million in promoter penalties assessed against our client prior to our involvement.
• Litigating promoter penalty refund cases in United States District Court.

Our experienced team of tax controversy attorneys is ready to defend you in promoter penalty examinations.   

EMPLOYEE RETENTION CREDIT (ERC)

The Employee Retention Credit was a key part of the  Coronavirus Aid, Relief, and Economic Security Act (CARES) relief provided to businesses.  Since enactment, it has been wrought with problems.  Businesses all over the country applied for the credit, and the IRS has struggled to process the claims.  The IRS has alleged that many claims are fraudulent, while taxpayers are unhappy with the pace (or lack thereof) of process claims for the credit.

Moore Tax Law Group is well positioned to represent taxpayers and preparers in disputes with the IRS over ERC claims.  Guinevere Moore has written extensively about this topic in Forbes.

CRYPTO CURRENCY

Get Crypto?  So do we.  We understand the nuances of cryptocurrencies and we accept them as payment.  We have defended civil and criminal cryptocurrency tax disputes.

APPRAISER IRC § 6695A PENALTIES

We have represented several appraisers in defending against assessment and collection of IRC § 6695A penalties.  Our team understands appraisal standards, methodology, and defends appraisers on procedural and substantive grounds.

REPRESENTATION BEFORE THE IRS, OFFICE OF PROFESSIONAL RESPONSIBILITY

Tax professionals turn to Moore Tax Law Group to represent them before the IRS, Office of Professional Responsibility (“OPR”) because we advocate for our peers as zealously as we advocate for our clients.  Our leadership experience with the American Bar Association, Section of Taxation, Standards of Tax Practice Committee makes us well-suited for these kinds of matters.  Guinevere Moore was a significant contributor to the 2014 Circular 230 amendment comment project, she was previously the chair of the Standards of Tax Practice Committee, and she is currently the Council Director of that committee.  Our understanding of the myriad of professional rules applicable to tax professionals and the procedural rules applicable to OPR matters, as well as our strong relationships with OPR make us well-suited for these difficult matters.  We have represented attorneys, CPAs, and appraisers before OPR.