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Tax Advocacy & Controversy Services

Baker Tilly provides IRS audit and appeals representation and supports IRS installment agreements and offers in compromise, requests for penalty relief, private letter ruling requests and IRS voluntary disclosures – offshore and domestic.

Tax Advocacy & Controversy Services

Baker Tilly specializes in IRS practices, procedures and controversy solutions. Our dedicated professionals help companies and individuals effectively and efficiently manage an audit, respond to IRS notices and other requests and strengthen their position with the IRS to minimize the risk of being selected for an audit.

    Strengthen your position

    Our team of attorneys and accountants has deep experience and knowledge gained from years of working with tax law, including high-level positions within the IRS. We offer advice on any actual or anticipated tax dispute as well as representation for IRS exams and appeals.

    We combine our understanding of complex tax laws and familiarity with tax agency rules with what we learn about your specific situation to develop strategies that lead to favorable results.

    Baker Tilly assists you with all aspects of IRS procedures, including initial response and representation, alternative dispute resolution, penalty mitigation and filing amended returns or claims for refunds. We also help optimize your planning and compliance, negotiate missed elections, correct errors and address other accounting issues.

    Our range of services includes:

    • IRS audits and appeals: prepare and respond to the IRS with experienced, informed and effective representation
    • Private letter ruling requests: address 9100 relief and other ruling requests to Chief Counsel
    • Large penalty cases: assist with failure-to-file, failure-to-pay, foreign information returns, penalties associated with Affordable Care Act compliance and more
    • Alternative dispute resolution: use IRS alternative dispute resolution programs like Fast Track Settlement to help you achieve the desired outcome
    • Amended returns or claims for refunds: present and document tax positions, properly complete required forms and negotiate resolutions 
    • Collection solutions: assist with offers in compromise, installment agreements, innocent spouse claims and trust fund recovery penalties

    Administrative adjustment requests for CPAR partnerships - FAQ and toolkit

    Partnerships subject to the centralized partnership audit regime (CPAR) cannot file an amended return to report changes to an originally filed Form 1065 – instead the partnership must file an administrative adjustment request (AAR). Download our CPAR AAR toolkit to understand what is required to prep your deliverable for the IRS.