The work we do
A CP15 notice can trigger a penalty assessment when the IRS catches a required Form 3520 or Form 3520-A that was not submitted on time and there was no extension. Our practice is built around analyzing the facts, presenting the strongest available position and managing the IRS process with you.
Practice areas
01
We challenge a penalty assessment triggered by a CP15 notice when the IRS catches a required Form 3520 or Form 3520-A that was not submitted on time and there was no extension. The case begins with the notice and the record behind it: what was filed, when it was filed and why.
02
When the facts support relief, we develop the reasonable cause, first time or other available abatement position, assemble the record and present it directly to the IRS.
03
We handle correspondence and negotiations with the IRS and can represent clients through Collection Due Process hearings, appeals conferences and Tax Court proceedings when appropriate.
04
We review original filings and reporting histories for omissions, inconsistencies or red flags that may have contributed to the notice, then identify the cleanest next step.
The appeal process
The process depends on your circumstances, but a carefully managed appeal generally involves these steps.
We review the CP15 notice, filing history and circumstances surrounding the penalty assessment it triggered.
We prepare a written statement outlining the relevant facts and legal reasons the penalties should be abated.
We file the appeal with the IRS office that imposed the penalty or the appropriate appeals office.
We respond to requests for additional information or evidence needed to support the appeal.
We represent you in further proceedings, including Collection Due Process hearings, appeals conferences and Tax Court matters.
A crucial distinction
When you speak with an attorney about your Form 3520 or 3520-A issue, your communications can be protected by attorney client privilege. That protection is different from speaking directly with the IRS or relying solely on an accountant for the defense of a penalty.
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