How to Work with the IRS: Strategies for Attorneys, Accountants and Appraisers

Part 1 introduces the book and presents information on the IRS official and unofficial rules of engagement to set the stage and help attorneys, accountants and appraisers understand how to work effectively with the IRS.  Having introduced this topic, Practitioners need to understand the IRS organization, how it has been stove piped, and how different cultures in the IRS require different approaches to various issues.   The author's background and best practices are presented with examples to demonstrate how this information can be used effectively when working with IRS employees.   Issue resolution and mediation mean different things to different people in various parts of the IRS organization. This is laid out for Practitioners when working with the IRS on issues.  Understanding the various cultures and approaches within various organizations can significantly assist the Practitioner when working with the IRS.   Finally, in this first part of the book, classification in the Large Business and International organization in general, and classification for estate and gift tax in particular are explained to assist the Practitioner in understanding how this process works at the IRS.   The author believes all readers will find these topics to be very beneficial.

 

 

Part two of the book explains how the various specialists in the IRS look at and approach various technical issues.   Topics discussed in detail are potential penalties on appraisers, reasonable compensation in closely held corporations, code section 409A and valuators, discounts for lack of marketability, the most common errors in valuations, strategic growth areas for business valuation appraisers and other engineering and valuation related areas.  The other areas include research credit, international tax issues, cost segregation studies, capital versus repair issues, real property valuation issues and other topics of interest.  The author believes readers interested in specific technical topics will find those topics of most interest.

 

 

Part three ties these topics together by first looking at strategic thinking and then bringing home major "do's and don'ts" learned from earlier chapters. All firms need to stop periodically, pause and think about where they are, where they want to be, and how to get there.  The chapter on strategic thinking looks at this from two directions. First, given the material in the book, what might the Practitioner want to do differently when working with the IRS? This element is relevant for all Practitioners.   Second, Practitioners with a background in accounting or business valuation might want to consider suppling strategic planning and value added services to assist clients as the author is doing in his practice.   The last chapter presents the most important lessons learned with a few more examples to help the Practitioner as a practical reference.  In the appendix a list of government speak acronyms are presented to help the reader navigate IRS jargon.