If you find yourself in litigation with the IRS, or in the middle of an administrative dispute that seems to be going nowhere, it’s time to consider a taxpayer’s best friend: the qualified offer. The qualified offer provisions allow taxpayers to recover fees and costs when the IRS rejects a settlement offer, and the taxpayers win a determination that requires a lesser amount than the offer.
If you are involved in a tax controversy with the IRS, you should expect that that the IRS will want your electronically stored information (ESI) and it will summons it. This article explains what ESI is, why it matters, what powers the IRS has to get it from you, and what you should do about it.
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