What does a tax attorney actually do between 'hired' and 'resolved'? Here is the engagement from the inside - the same arc, case after case, for 32 years.
Week One: The Record
The power of attorney files immediately, rerouting IRS contact through counsel and unlocking the real first step: pulling every transcript and reading it four ways. The clocks - every assessment dated, every collection statute expiration computed. The composition - each balance decomposed into tax, penalty, and interest, mapping what is removable. The posture - liens, levies, prior offers, what the IRS is actually doing and what comes next. The errors - misapplied payments, miscoded tolling, balances outliving their statutes. Everything after is built on this read, which is why settlements quoted before it are fiction.
The Middle: Sequence and Negotiation
The phases run in the order that compounds. Compliance first - missing returns built from the IRS's own wage records, because every program is closed to non-filers. Penalty abatement before anything prices the balance - first-time abatement aimed at the biggest stack, reasonable cause built as an evidentiary file - so the agreement or offer downstream negotiates against the smaller number. Then the exit the math supports: the streamlined or negotiated agreement, the partial-pay structure that lets the statute win, the offer in compromise where the calculation genuinely clears, the hardship determination where it does not, the bankruptcy referral where the timing rules beat everything. The negotiation itself is mostly documentation: IRS decisions are made against written standards by employees who must justify their answers, and the file that meets the standard wins.
The End: Paper and Permanence
Resolution ends in documents - agreement terms, offer acceptances, determination letters - each checked line by line, plus the unglamorous final phase that keeps the problem solved: withholding or estimates fixed, the compliance calendar set, because one new unpaid year defaults nearly everything. That is the work. The free consultation here runs a miniature version of week one on your facts, and you leave knowing your position either way.