Audit defense
Preparation and representation for document requests, examiner communications, issue development, and audit response strategy.
Practice Page
Tax controversy representation when the file is active.
Controversy work begins with control of the record: notices, transcripts, deadlines, documents, facts, and procedural posture. McClintock Tax Law represents taxpayers before the IRS, state agencies, appeals offices, collection personnel, and the U.S. Tax Court.
Scope
A controversy file needs a procedural map.
The first question is not only what happened. It is where the matter sits, what deadlines control, what agency function has jurisdiction, and what evidence is needed before the next communication.
Appeals
Administrative protests, hazards-of-litigation framing, settlement positioning, and conference preparation.
Collections
Resolution paths for balances due, enforced collection, trust fund recovery penalties, liens, levies, and payment alternatives.
Tax Court
Petition-stage assessment, pleadings coordination, substantiation development, settlement work, and litigation strategy.
Deliverables
What clients typically receive.
- 01Notice, transcript, deadline, and procedural posture review.
- 02Issue chart separating facts, law, documents, exposure, and response options.
- 03Agency communications, submissions, protests, petitions, or settlement materials as appropriate.
- 04Closeout memo and forward compliance plan after resolution.
Next step
Do not let the notice set the strategy.
If you have an IRS or state notice, audit letter, levy, lien, summons, or Tax Court deadline, preserve the timeline and get the file reviewed.