Ep. 2 | Best Practices for IRS Representation
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John Tripolsky:Hey, everybody. Welcome to the second episode here on the Mr. R. Show. I am John Trypalski from the team over here at the Monthly Recurring Revenue Institute.
John Tripolsky:You're always gonna hear me and Chris Pacuro, our founder, on these shows. Usually, it's gonna be us with a guest. Sometimes, it'll be by ourselves. But today, we have a fantastic guest as you will hear me say all the time, but I mean it about this gentleman. Really, I mean it about every one of them.
John Tripolsky:They're all great or we wouldn't have him on here. We're bringing on Andrew Pulos. So, Andrew runs his successful practice down in the Atlanta, Georgia area. He's probably the best guy in our quote unquote Rolodex, if you will, as it relates to diving in to very, very specific relationship management tactics, if we should say, with the IRS. So again, topic for today, best practices for IRS representation.
John Tripolsky:Andrew's gonna join us here in a moment. Chris has known him for a very long time. They've worked together on numerous projects. You'll hear some of those stories here shortly as well. We have a great conversation coming up.
John Tripolsky:But, really, I'm gonna sit back on this one. Can take a little bit of a back seat. Let these two gentlemen really talk through their experiences. You're guaranteed to get some fantastic little knowledge nuggets from this one. So grab the notepad, grab the pen, grab a glass of water or coffee, sit back, and enjoy the show.
Chris Picciurro:Hey, Andrew. Welcome back, my friend. I know we have spoken before on the Teaching Tax Flow podcast. We did a great episode. I believe we've referred to the IRS as Darth Vader.
Chris Picciurro:So if you ever heard that podcast, jump over to Teaching Tax Flow. You'll find it there. But this one's a little bit different because we're gonna talk about it as far as for managing that relationship representation with the IRS. And me and Chris had spoke obviously previously a lot before recording this one with the monthly monthly recurring revenue institute. I can't even get MRR, baby.
Chris Picciurro:It's almost like IRS is too simple, so MMRI gets more complex. And we couldn't think of anybody better than yourself to talk about this with. Because, obviously, the IRS is not gonna come on with us and tell us all their secrets, all the ways that we could, you know, win in the battlefield, quote, unquote. So before we do that, though, people know who you are, but tell us
John Tripolsky:a little bit about yourself, really how you got into this, how you became you
Chris Picciurro:know, we'll call it, you know, screw it. We'll just call you the megastar. The megastar and representing Master Jedi. Yeah. There you go.
Chris Picciurro:We can use with the Darth Vader. It's awful because I don't know anything about Star Wars or Star Trek. Believe my art wars. But, anyways, enough said. Andrew, how'd you get into this, my man?
Chris Picciurro:How how did you get into this field? How did you build up your expertise in it?
Andrew Poulos:Fellas, good to see you again. Yeah. You know, it's just a lot of, you know, when you get into representing, clients for tax resolution matters, man, is, training and, hands on experience, right? I mean, you've got to take on cases to to learn how to work them and no two cases are the same really in essence because you're never gonna probably have, for the most part, the same revenue officer or revenue agent, you know, depending if it's an exam or a collection case. And so, you know, you gotta dip your toes, so to speak, into the, into the playing field then and kind of learn it.
Andrew Poulos:But there's a lot of training out there through associations, where they offer tax resolution. So, yeah, going on twenty eight years, certainly, I I wouldn't yeah. I would say go out on a limb and and call like you guys being the the last four expert, but, you know, you, trial and error, you you work on it and try to do the best you can with helping, the clients that you're representing.
Chris Picciurro:So Andrew and I met on the Intuit tax council many moons ago. We hit it off well. We always enjoy.
Andrew Poulos:Oh, Martin. So it seems like ages ago.
Chris Picciurro:It hasn't been that long. It hasn't been that long. I don't no. You're right. But we just clicked.
Chris Picciurro:And can you tell us about you know, obviously, we're talking to tax professionals. Tell us about your private practice. I know you work with clients all over the country, based in Atlanta area. Big Braves fan, as well, which is very easy to be, at the time of this recording at least, unlike my Tigers. That's alright.
Chris Picciurro:We won't go on that tangent. But, yes, can you tell us about your, you know, your private practice a little bit and, how you got got started?
Andrew Poulos:Kinda like a lot of other, tax pros. I mean, I do a little bit of everything from tax prep on individuals, corporates, partnerships and whatnot, consulting services, you know, but a lot of what I focus on is tax resolution. Inevitably, yeah, what's going on with the IRS, coming out of pandemic, notices are, you know, just kind of coming out of like floodgates. So, you know, taxpayers just need help. So it really depends.
Andrew Poulos:But overall, just dealing with predominantly what we do is deal with a lot of small business clients. Not necessarily we don't deal with individuals on a ten forty side, but you know, small business clients pretty much. There's a lot of what we do, both, you know, planning tax rep and, of course, post tax rep with issues that come around.
Chris Picciurro:And this works for working with the IRS. So obviously our audience is kind of split, right? We have some individuals that are
John Tripolsky:newer into the tax pro space, some
Chris Picciurro:of the ones that have been around for a very long time, so everybody may approach it a little bit differently. I'm going out on
Andrew Poulos:a limb here a little bit
Chris Picciurro:because I am not a tax pro by any stretch of imagination. So as far as for like, we spoke about, you know, in pretty pretty good detail on the previous podcast we did as part of teaching tax flow. When these notices show up, obviously, sometimes people freak out. Right? They or worse, if you haven't listened to that podcast, you'll hear us talk about this about 1,500 times is not doing anything with it.
Chris Picciurro:So as far as for from the tax professional side, I mean, what's something they might be able to do as far as for, we'll call it calming a client down or or really alluding to the fact of, you know, maybe that maybe the preparer didn't do anything wrong. They just happen to get a notice that, you know, obviously needs to be resolved somehow and that's maybe the case where you come in. So maybe walk us through a couple of those scenarios with some tips in there possibly.
Andrew Poulos:Yeah. Look, as a preparer, you're either dealing with a notice that a client's gonna get for return you're prepared or you might be picking up a client who has sought prepared and gone elsewhere that somehow found you, got referred to you for, tax resolution. Right? We say tax resolution could be a notice, something very minor, it could be an audit, it could be a collection case, you know, where someone falls to return, there's a balance due afterwards and they need some assistance. So it's it could be a variety of things, but, like, you gotta be the calm voice, you sort of speak in the situation, whether you're prepared to return and there's a notice that's come in, and I think that happens to all of us if you stick around in this profession long enough, right?
Andrew Poulos:You know, you can't prepare returns for, you know, in your entire career and not expect that someone's not gonna get a notice. And it could be your fault, it may not be your fault. Right? It could be Trish will probably tell you where the client forgets to give you something and you prepare the return based on information given and then the client gets a letter and of course then you try to diffuse sort of situation from it becoming a blame game. You know, you just got to be the big person and professional, try to figure out how to assist and resolve the matter in case you return your prepared.
Andrew Poulos:If it's a return prepared by someone else, you got to figure out, you know, essentially you know, what work was done, what the issue is, how to call in the taxpayer. Most people start freaking out, of course, particularly if it's an audit. And I think moving into the future, we'll probably start seeing more of those. Probably a lot more correspondence exams, but there are gonna be some field exams. Everything, with the ERC credits going on, a lot of, you know, scams of fraud from Mills out there, So there's gonna be a little bit of everything out there, but at the end of the day, it's just no different than a person who's not well, goes to the doctor.
Andrew Poulos:You gotta be that calm voice pretty much, and reassure them that everything's gonna be fine. You know, at the end of the day, depending on the situation, you really can't promise things. Just don't know how the situation turned out for the most part, but you got to keep the client calm in order to be able to be effective and get them to do their part, whatever their part might be, you know, in that situation, whether it's gathering documents, you know, having made, yeah, just some sense and logic for them not fear the situation, right, and go from there to try to resolve it, in the best possible.
Chris Picciurro:So for our tax professionals listening, guess what? Your clients aren't the only ones that forget to give you information, and your clients aren't the only ones that, assume that you did something wrong or that the sky is falling if they get a letter from the IRS. It happens all the time. And, obviously, as tax pros, we could touch on this a little later. Odd is we need to do our best efforts to avoid the notice before it exists.
Chris Picciurro:But kind of talking about field exams versus correspondence exams, can you touch on kind of the hierarchy of seriousness all the way down from a from a CP 2,000? Maybe or we actually probably lead the the best notices, Andrew, you probably chuckle at or the, hey. We've got your stuff. We need sixty extra days to look at it that we're just giving you an update, until sixty days if I was buying. Then you get another one that says, hey.
Chris Picciurro:We've got your stuff. We need sixty extra days to look at it. But and as funny as it sounds, the first thing you should do when you get a notice, I this and then then I call Andrew, is open it up and read it. Right? How many times it's like they're afraid to open it up.
Chris Picciurro:But, if they do get something in the mail, can you talk about the seriousness level from, like I said, from the less serious to very serious? One more thing, and we want peep the tax practitioners to be aware of too to help their clients is how does IRS typically communicate with people? Because they don't you know, we we hear there's a lot of scammers out there calling people, showing up into at doors and and and that sort of stuff. So how does IRS typically communicate with people? Then what what does that look like usually with the level of, seriousness?
Andrew Poulos:Yeah. Listen. You're gonna see a little bit of everything you you stick together in this profession long enough as a tax. Right? I've got I've had clients follow-up, you know, business owners freaking out, being told that the sheriff's on their way to arrest them if they don't send x amount of dollars in, you know, within the next, you know, twenty four hours.
Andrew Poulos:You'll see all kinds of, you know, scams, nonsense in a sense. So you gotta be prepared and always you gotta be the, the voice of reason and calm pretty much to calm the taxpayer down and reassure them that that person is not the sheriff. It's not the FBI going after them, so to speak, right? The IRS doesn't make outbound calls unless it's a revenue officer or a revenue agent, but they still have to make contact via letter. And usually, if there's a power of attorney on file and the tax professional is representing a case or matter, then they're going to communicate or should communicate with the tax professional power of attorney versus reaching out to a taxpayer directly unless they just really have tried and attempted and the tax professional is non responsive in a sense.
Andrew Poulos:But overall, look, every letter, every correspondence we'll call it from the IRS is important. Worst thing that someone can do, any taxpayer, any of your clients can do is just really get letters and not we're gonna open them up and just kinda put their bury their head in the sand and be like, Well, you know, this will go away or if I don't look at it and I don't know, then I don't have to worry about it. Most of these notices, depending on what they are, are time sensitive in a sense, right? They'll give you thirty days to respond, agree or disagree. Like this just a proposed change.
Andrew Poulos:From there, if it's an examination, you've got to open it up and know what's going on. And if it's an exam, then you've got to figure out how are you going to approach it, right? Go out and tell the person you who did the, the tax return or maybe you hire someone that person is not experienced or doesn't deal with examinations, most spiraling. So there's gonna be a little bit of everything, out there. But, you know, it in a sense to me for me, personally, it's just a little bit easier if the exam is, you know, with a revenue agent field exam or in office, in person we'll call it, right?
Andrew Poulos:Because you have communication, you have a direct line of context versus a correspondence exams where they send you a letter and they ask for know, just everything under the sun and then you got to mail it in and wait to see if someone reviewed it and then you're not going to get a response potentially and then they're going to send back and tell them, hey, we never got your information. Meanwhile, you're sitting out there waiting and you're signing off. Right. So it just, you know, it's essential to take experience and skill on figuring out, you know, most of the challenges is knowing how to navigate the system, and besides just knowing the rim of the walls and being able to apply them. That's where our clients can't do it on their own.
Andrew Poulos:You know, most of our plaques would even know how to write, you know, a nice professional letter to articulate what we want to articulate to the government in a sense. So there's a little bit of everything. There's a lot of challenges out there. But overall the most important thing is you got to read the notice. Open it up, read the notice, and take action.
Andrew Poulos:Contact someone, you know, that can assist you, and do it in the timely manner before that time runs out.
Chris Picciurro:Will the IRS email people? No. Right. I know. I I'm just you know, there was a lot of scamming.
Chris Picciurro:Out there. That's that's the thing I I see.
Andrew Poulos:And and these You know, right now, a lot of these scams are misleading information is what these ERCs going on still. Right? You still have time to be able to retroactively go back and file, you know, for ERC credits until next year. And so there's just so many scams on your, you know, weekly calls. I think we all do.
Andrew Poulos:So Mhmm. Plan. Hey. You know, I think I all filed this. Oh, well, my buddy did this or my boom.
Andrew Poulos:My buddy went to this company, you know, and they got him, you know, 200,000 lots. Look, you know, with and I bring this up because time and point we're at now, you know, there's the word on the street is that if anyone filed in for ERC, the letter the IRS is subsequently after they issue the credits, we're sending out a what we call soft notice, right? We're kind of preparing for an audit. So they're gonna come around and send you a letter, you know, lightly say, Hey, can you tell us how you came to the conclusion that you, what facts did you use to determine that that your business qualifies for the or the ERC? And depending on what you tell them, what you don't tell them, and how you handle that could, you know, lead to an examination.
Andrew Poulos:So that thing moving forward, we're gonna see a lot of, you know, in the coming years, a lot of exams on ERC and the IRS is going to have, you know, long enough straight into the future to be able to audit them. But that's not to say that we're not going to see exams for, I had one of our overachms that, we prepared that I prepared, you know, a year and a half ago and it was on a C corp. Right? And what we discovered was that, in dealing with the revenue agent and she was very responsive, that there were she had quite a few C corp exams and had to deal with, with retained earnings, accumulated earnings tax, something that the IRS hasn't touched, for, for the, AA tax in a very long time. So you you learn know how to navigate the system and deal with the revenue issues and you back some data, and you work with them in your professional.
Andrew Poulos:A lot of times you'll figure out a few things from them that could help, you know, on other cases or other clients. So that's kind of my approach. Approach. There's everyone's got their own approach. I've seen a lot of stuff in mind twenty eight years again that we all have to, you know, learn how to navigate the process and then what works best for us as to how we we work with the IRS.
Andrew Poulos:We have to work with the they We can call them Darth Vader. We can do whatever. But at the end of the day, all jokes aside, I mean, you know, it's the other side and we've got to reach for us. We all don't be able to work together.
Chris Picciurro:And Andrew, you mentioned, you know, a couple couple examples that kind of circling them all together. So as far as for, you know, the various types of scams that are out there, obviously, those are likely gonna get more will make the assumption more intrusive, more professional sounding as time goes on. Obviously, technologies, you know, plays a huge part of that. But then also you mentioned with the ERC credits. So it's almost the the expectation is that if I heard it right, the likelihood of an audit goes up significantly or at least an examination to some point if you file for that.
Chris Picciurro:So maybe something from a not going into practice management for the most part for our audience, but maybe a suggestion with that be is trying to actually get across the information, like you just said, to all of their clients. Right? Now may that be something on a website, something in an email that, you know, normal correspondence with their clients and kinda letting them know that, hey. This is still going on. This is what we're seeing more of.
Chris Picciurro:So almost alleviating the, oh, crap. I just paid $50, you know, in in Bitcoin to Steve, who said he was down the street from me. They were gonna arrest me, and then coming to the Tax Pro saying, hey, that this just happened. So almost building up, you know, obviously, their credibility and but, in a sense really strengthening that relationship with their client. Right?
Chris Picciurro:Is that something you'd recommend as well?
Andrew Poulos:Yeah, absolutely. Listen, you know, the one thing we can say and we all should know but don't is that with technology, the scams and the crooks are just gonna get more sophisticated. You know, it's just a matter of time, right? You got AI out there. You can do all kinds of, you know, just scams and all sorts of stuff, right, and be very efficient.
Andrew Poulos:You got Chad G and T now is coming into our profession and everyone's lives. So you have to expect the unexpected. And we're going to be challenged because we're going to start having clients in the future, maybe not today or tomorrow, but we're going to start seeing having clients in the future where they're going to start calling us and saying, Hey, I saw this where I got that. And this is going to be something new for us as well. We perhaps have not seen that scam or heard that scam, right?
Andrew Poulos:So you have to be aware. You have to be mindful as professional and advise your clients. I always try to on the side of caution sort of speak to where I'm unsure. I tell them not to do something until I sort of can do a little digging and figure out, man, is this legit or is this a scam? Something I've never heard of, right?
Andrew Poulos:But yeah, with ERCs and I still mention that because that's the modern day, you know, hook and line and sinker, so to speak, these people. These are small business owners and look still looking for money. A lot of them need it. Others do not. But, you know, when it's money on the table, they're not being informed by even companies out there that may be legitimate.
Andrew Poulos:You know, I've seen misadvertisements like, you know, you qualify for this and your business qualifies for 27,000 or whatever the number is, right, per employee. A lot of these people still think, for example, that, you know, this money is still free money, just like PPP was and it's not. And there's the sticker shock afterwards, right? There's the after effect. You have to amend returns.
Andrew Poulos:You can owe some taxes as to where to see which most of these small businesses are. It's gonna affect their personal loans. There's a lot of amendments and violence and fees. So, you know, I always tell my clients, Listen, this is, you know, a situation. You got to make an informed decision.
Andrew Poulos:Even if you do qualify, you still should expect potentially, you know, that you may get an exam afterwards, right? So is it worth, you know, depending on what you your business qualifies for, is it worth, you know, the whole process and the exams and the additional fees and representation and the stress you're giving in Derby's most ninety nine percent of the people are gonna endure stress being under examined and having, you know, their life dug up in those steps. Right? So you'd have to be upfront and and with clients, whether it's ERC or anything else, and I always try to advise of the, you know, the pros and cons, the risks, you know, versus, you know, the benefit. But, you know, I I we're it's all evolving and time's changing.
Andrew Poulos:I think in the future, you know, speaking of scams, we're gonna see the IRS getting much more sophisticated to where they're not gonna need potentially as much manpower because AI is gonna come into the equation. They're gonna be able to do exactly what we're doing just like we're gonna use chat GBT to celebrate, you know, our, capital gains, see, you know, equation for us and transaction. The IRS will be able to use artificial intelligence to track people and figure out who's not under reporting, who's not reporting, you know, the whole nine yards out there. So we'd have to be mindful, moving forward pretty much of how the landscape and the playing fields would change.
Chris Picciurro:And if you're, yeah, if you're implementing a we are big advocates of of partnering with specialty tax firms and implementing some, advanced tax strategies like cost segregation studies or ERTC or r and d credits. That said, when when those calculations are are are put together, you have to just assume you're getting on it. Don't think two years later you're gonna remember how that was calculated. And some of these fly by night, you know, ERC ERTC Now LLC, we think you have four employees, so we're gonna mail you a fake check-in the mail for your for your, you know, $9 or 27,000 employee. And and it's too bad because, you know, the the thing is most of the people that are listening to this podcast, it's like preaching to the choir, are the are the good practitioners.
Chris Picciurro:And, unfortunately, the peep the the taxpayers that that get taken advantage of typically don't go to the good practitioners. But but that's, you know, that's a good point. Preparing you know, obviously, you don't no one likes to get audited, but but it's it's a numbers game. And, you know, if if you do get a letter in the in the mail, you know, what you don't do as your taxpayer is invite the IRS to your house for some milk and cookies. I'm like, hey.
Chris Picciurro:I actually have the last seven years of all my documents available and put it on a table and then answer any questions that they have. You know, find the proper representation. It's it's if if you're a tax pro, if you're a tax pro that you do representation, we're great. If you don't, find someone like Andrew to partner with, and and make sure they have the taxpayer has the right representation because it's just if you don't know it's not that we're trying to be dishonest, but what what I see out there and, Andrew, I'd love to get your opinion or or your advice to people is, first of all, give the IRS what they're looking for. But you don't need to give them more because, essentially, if you're getting you reviewed for something, you ought to limit this.
Chris Picciurro:The first step is on it's kinda defense. Right? You might they they got runners runners on base. You gotta get the guy out. So how how could a tax pro, work towards limiting the the scope of the examination for the current year and limit it to only one year and not any other open years?
Chris Picciurro:And what if there are tax returns that are on extension and then you're in the middle of the audit? Do you have a recommendation if those should be prepared or held off on? Great question, Chris. And,
Andrew Poulos:you know, it's what works in one scenario and in one case is not gonna work worse than the other, right? Even if we're the same ones representing. I say all the time, it really depends a lot of the outcome, you know, good, bad, or indifferent, with tax resolution cases. Sometimes depends, you know, on us and on our abilities and experience and how to navigate the process. And a lot of times it also depends on the other side, who your revenue officer or revenue agent is.
Andrew Poulos:It's just now and to some extent, if you stick in this professional enough in a tax resolution, in your area, in your district, so to speak, right? You get to know people, these agents, revenue officers, and you deal with the whole and over. And, you know, if you have developed that rapport, you know, that relationship, in a sense, working relationship, you know, sometimes it becomes life becomes a whole lot easier, you know, for you and your and your client. And this thing, you know, and then you'd learn to Google which agents and which revenue officers are easy to work with, which ones you don't really like that much. Right?
Andrew Poulos:And you and you did have a good experience last time. But overall, you know, I've had some great success and, you know, partly because I just knew that revenue agent from a previous audit or that revenue officer. And they either like me or they trust me, you know, they see me as credible. And so, a lot of times that helps from, you know, steering the ship from left to right, so to speak. Right?
Andrew Poulos:But, you know, in a sense, we sort of partly have some control in a like, let's just take an exam. In the exam, when you get that IDR, that information document request, you or your client, it's gonna be asking for everything under the sun. You know, probably nice hefty two pages, you're stretching your head and thinking, man, like, you know, the taxpayer's stressed out. They're asking for everything under the sun. No.
Andrew Poulos:That's how we got started with this C Corp exam that I had, recently. And so I told the agent, Clint, I didn't know her. I've never worked with Hertz, but, you know, she was from industry, and had started with the service, just more recently, we shall say, but overall, I was like, listen, I said, you know, this is in a sense, you know, just insuranceship, you really need all this information and then can fine tune it. And she's like, yeah, I entered a lot of problems, Sure. With business and business.
Andrew Poulos:I said, You know, we're on extension for this. I think this was a 21 return. It got pulled like literally within ten months of when we filed it. And we were on extension for or twenty, I should say. Sorry.
Andrew Poulos:Twenty at the time. And we were on extension '21. You know, are you gonna pull this '21 in yet because we haven't filed it yet? And it was right at the extension deadline. And she said, look.
Andrew Poulos:She goes, I'm gonna be brutally honest with you. Depending on what I find or I don't find, it's gonna determine basically if this becomes a multiyear exam or it doesn't. You know? I'm like, alright. Sweet.
Andrew Poulos:So, you know, we sat down, had it heart to heart, went through the initial interview, just myself and the agent, and I started to sort of feel her out and figure out where this might go, where it may not go to sense, right? And we started discussing issues. And, yeah, Randall caught a break. Right? She was really easy to work with in a sense.
Andrew Poulos:A lot of what I was concerned about that I had prepped the client of potential issues, you know, not that the return had anything materially wrong, but potential issues. Right? But you gotta people have to understand, I suppose, have to understand that, you know, even a small, deduction with the if a revenue agent wants to make an adjustment just so they can have something on on the books and on their exam sheet, you know, on their auditors report that they've made adjustments. That's their job, to make adjustments, generate monies, not to collect money. That goes off, you know, gets assessed and goes off to the to a revenue officer to collections at that point.
Andrew Poulos:But overall, getting back to it without getting into long drawn conversations that, you know, it actually went better than we expected. And at first, she told me we needed to file a 21 return before we got it to the exam. Guess what? We didn't have to file it at the end of the day. We didn't have to file a 21 return until the exam was pretty much done.
Andrew Poulos:So it's just really about navigating it. You know, maybe we'll call it a lucky break. Maybe it was just, you know, the way that we approached it. Maybe it's that we had a good agent. You know, but overall, you know, there was potentially some issues there, and she just pretty much told me there were non issues for her.
Andrew Poulos:She was basically her attitude was like, listen. I don't find what I'm looking for in my main, on my main topics that I'm not expanding. Didn't we minimized it and steered the ship, so we minimized it. So when your exams got done probably, I'd say, in about less than ninety days, which is almost unheard of these days. Right?
Andrew Poulos:So you can actually get good results. You can knock out exams where there've been no changes. People often think like, okay. I'm the you know, I'm just gonna get railroaded by the department here. I'm under exam.
Andrew Poulos:That's not often the case. You know? The most of the times you can make adjustments. And if you've done, you know, something wrong underreporting of income or something, you know, overreporting expenses, Yeah. They're probably gonna catch it if they're skilled at the revenue region.
Andrew Poulos:But overall, man, you know, it's not not everything is the end of the world sort of, you know, doomsday just because someone, you know, is under exam, with with the IRS.
Chris Picciurro:Well, I have a no. Thank you for that. So and and that brings up a question I have as far as a revenue agent. Two two part question. Let's assume, you know, your your your tax practice is national, and you're working with a client from, oh, I don't know, let's say, California because we gotta fluke that.
Chris Picciurro:Now you you might wanna know. But let's say they live in let's say they live in Texas, and, obviously, you're based in Atlanta, and you prepare the returns. Let's say you prepare the returns. They get examined. They you get contacted by a a field office in Texas.
Chris Picciurro:Can you move that exam to Atlanta? And and can do you also have any rights to request a change of revenue agent? Now we do understand that's the equivalent of sending your food back to the kitchen and and, you know, and sometimes that could get get bad when you get your food back, but can you just kinda touch on touch on that for us?
Andrew Poulos:Yeah. And you would in that situation, probably would request a change of bank. Now you have to have a reason as to why you want a change of bank, meaning from the Texas office to the Atlanta office. Right? And your main reason is gonna be because all the books and records are at the tax professional's office, not with the taxpayer.
Andrew Poulos:And usually most of the time the IRS will grant that unless there's just some reason or something going on behind the scenes that they're not going to divulge to you. So you want to try your best, of course, to have a change of venue for a couple of reasons. One, you want to minimize your tax payers, your clients, you know, representation fees, right? Because if you have to fly out there or drive out there or whatever and be out there for a couple of days, that's going to drive up the client's cost. And number two, potentially, again, if you are in the field of doing tax resolutions, tax representation, and you've got a rapport working relationship with agents in your local district, your local office, you just might get lucky and you might be working with someone you've worked with before, which is then effectively that makes that exam a whole lot potential, a whole lot easier, a whole lot more efficient, and and you know, the the processes to minimize our, you know, collateral damage, right?
Andrew Poulos:Minimize our taxpayers' adjustments or tax bill, so to speak, you know, in an audit and try to get that closed out as as quickly as possible. The less time, you know, that the audit stays open, probably, you know, the less risk in a sense for the taxpayer.
Chris Picciurro:Can you take a then thank you for that. Can you take us through us? Let's assume you you have an exam. You you and and you and I know that, and you do way more work than I do in this, but I've had a couple situations where and I'm sure the the listeners have. The the revenue agent is is not that experienced, that doesn't have a lot of authority.
Chris Picciurro:They basically slap a big tax bill on you and you and you at that point, you're gonna request, an a manager would it be a managerial managerial review or an appeal? Can you take us just through a little bit of the appeal process if you disagree with with with anything in the in their findings? And then, and then if you disagree with that, what how you can I mean, obviously, it's more expensive, more time to take it up the food chain of appeals? But, let's assume that you have a very strong case and you feel like it would just that that the agent might not understand the law and and the rules as much as you do, and you really wanna talk to someone with more experience.
Andrew Poulos:Yeah. Listen. There's a variety of things here to kind of, you know, just, dissect your question, Chris, in your in your in your in your comments. When you take on a case, whether it's your own return, a lot of tax pros don't like to represent their own for, you know, conflict of interest, ethical issues or whatnot. I I I've been blessed, I guess, in a sense, right?
Andrew Poulos:My twenty eight years, I probably have had two of my own returns pulled of all time. So statistically speaking, I run a pretty low ratio. I've represented way more that have come to me for exam for solar panels. And I try to keep it like that. But overall, you have to do a risk assessment and figure out, you know, based on the IDR, where the government potential, where this case is gonna head to.
Andrew Poulos:You know, what are the issues? A lot of times you'll ask a revenue agent upfront. I will certainly I'll ask him point blank. I'll put him on the spot. I'll, you know, and I'll just ask him, why, you know, as a taxpayer being audited?
Andrew Poulos:And some of them will tell you point blank, this is the reason. These are the issues we're looking at we're gonna be looking at, and others will kinda just sort of, you know, be a little bit of basic then and those are the ones you want to be concerned about. You just don't know what the government's looking for, what they're gonna target in a sense. But overall, you know, listen, man, we're in the day of technology, social media, you try to figure out who the opposition is in a sense, right? Who the agent is, their expertise, their well-being experience, how long they've been in either in the field, in the profession, how long they've been working to the government, you know, training, not, you know, this is probably not gonna sound good, but in a sense, right, the training that IRS personnel are getting these days is far different and probably not as good as it used to be.
Andrew Poulos:Deal with a lot of those experienced revenue agents, revenue officers who have been around for twenty, thirty years, thirty five that are soon getting ready to retire here in the next couple of years, and they're very skilled. They've got great training. A lot of times, they're much even though they may know, you know, you may worry that they know more than you. A lot of times, they are much easier to work with than someone who's newer and is trying sort of to, you know, prove a point or create their path on their job and career. But overall, you gotta figure out how to navigate it.
Andrew Poulos:You know, if you've got issues if you've got issues, if you take on a case, I was just say, and you sit down with your client and, you know, you got to figure out from a to z what are the key other words, right? Obviously, they're being audited. So there's a reason that they got audited, you know, systematically, the system probably pulled them for exam and then, you know, got reviewed and and and there's a risk assessment that the government does. Right. Probability.
Andrew Poulos:Right? Probabilities for tax liability. And, you know, from there to end, you know, that that person who reviews it, the reviewer says, yep. You know, we've got a good probability of making some changes here and get some tax dollars, so we'll put this under exam. Or, no.
Andrew Poulos:You know, it's a little probability, so they move it along. Right? Or else we just never see because they don't really get pulled for examiners. But once they you gotta figure out, you know, is is there potential damage here? And if it is, how are you gonna steer that ship and try to minimize that damage and that risk for the taxpayer?
Andrew Poulos:And a lot of times it just may be from the very end's onset. I've had a case that I took on, you know, years ago and I told the clients that, you know, this is not going to end well if the revenue agent starts to dig deep. It was a small business owner, self employed, those are usually the ones with the biggest risk, of course, as we know. Then that it would be far better if we can just get to appeals because I just know in appeals, you're gonna get your break somewhere, right? It's just the way the system works because when we, you know Chris, you mentioned earlier about managerial, you know, review and whatnot.
Andrew Poulos:In my experience, and this is my experiences, that if you have an agreed upon issue an un agreed upon issue with the agent and you tell them, Hey, you know, I'd like for your manager to review this. 99% of the time they're gonna come back and the manager's gonna side and stick with his or her revenue agent, right? They're gonna they're gonna stick with that and they're gonna force you to play your car. And so, you know, there's a lot of what goes on in exams is negotiation. A lot of times people, you know, don't believe this, right?
Andrew Poulos:Tax pros who have never really dealt with this a lot, you know, think it's just all black and white. And a lot of times it's like, Hey, listen, you cut me some slack on this deduction or on this issue, you know, we'll concede to this. Right? And so you try to basically word your way through it. But if it's a case where you cannot agree to ends and it's materially off when you feel it's not in the best interest of your client, you know, you'd have a discussion with your client.
Andrew Poulos:And, yeah, while it may cost more representation fees. It just may be the best result that you can get for the viz to say, you know what, close this case out. We'll close this case out as an agreed upon. Give us our notice, our agree or auditors report, basically, and we'll file an appeals case. And a lot of times you'll see, you know, there just depends.
Andrew Poulos:Right? They, you might get a call from the vendor say, hey. How could we work this out? Because they don't want you to go to appeals. Or a lot of times they're representing a general circuit.
Andrew Poulos:You're fine. You know, You know, he or she feel they've done their job. They've got a nice, calm, agreed upon case with a bunch of adjustments and then you go to appeals. So we went to we had a case. It was a multi year case years ago and a small business owner said, You know, we came we basically strategy was to come out as unagreed.
Andrew Poulos:Our chances would work better with appeals. And, the case was I think we came out of, two year and it was unagreed upon well over $600,000 of liability. It'll let anyone not sleep, but I was very confident that that's not where we would end up at at the end of the day. We went to appeals. We prepared a great package.
Andrew Poulos:We shipped it off. Got lucky. We got I got an appeals officer who I've worked with before. He and I had been working relationship, and, we were on first name basis, so to speak. And we got there, and we sit down and he's like, Andrew, he goes, I appreciate you putting this package together.
Andrew Poulos:He goes, This is the government, the auditor's package. He goes, I couldn't be able to make sense of anything. It was so sloppy and messy, right? It was a NOR agent. We came out of appeals, Chris.
Andrew Poulos:We went in over well over $600,000 out, came out of appeals with, I think around $128,000 And that was actually very fair considering, you know, the taxpayer. The issues that we potentially have. Right? So, you know, I had already prepped the taxpayer. It wasn't a return.
Andrew Poulos:I had prepared. They had come to me, basically, and found it for representation, and and that was fine. They were, you know, they were happy with those results, you know. It can't be a small business owner and do things you're not because if the if the law gets you, it's just not gonna end well. But the you know, it was such a the case was impressive in a sense that because of the relationship that the work relationship I had where I had with the appeals officer, that when we put such a good case together, a very clean freight forward, conceded the things out of appeals, right?
Andrew Poulos:This was a substantiation case. Did they have, you know, no receipts for everything? The agent wanted a receipt for every single thing. Now can you imagine being a small business owner, a two year exam and a revenue agent is wanting a receipt for every single thing from $15 to, you know, tens of thousands of dollars. It's just almost impossible.
Andrew Poulos:No small business. No. No. And so I just knew when we got to appeals, if we showed that we had done enough to work with the revenue agent, we would get to appeals. And guess what?
Andrew Poulos:Appeals has had the chance, there was always the risk. You're not warned the client that if we don't show we've worked enough with the revenue agent, appeals could remand it back down to exam, back to the agents, say, Hey, y'all haven't worked enough. Just go back there and work with the agency if you can come to a resolution. And indeed, we didn't have that happen, but when I told her to close it out, I said, I'm agreed upon after I felt we had done enough to try to work with the other side. Manager calls me up and she's like, Mr.
Andrew Poulos:Poolis, you know, is there anything we can do? I said, No. I said, There's nothing we can do. I said, You're not conceding to anything on mileage logs. You're not conceding to anything.
Andrew Poulos:I said, Clearly, there's nothing for us. I'm not going to concede or agree upon one issue when we can't we have, you know, just the other issue, right? And we've got two appeals and we pretty much went from having to substantiate every single thing to having to substantiate 10 checks for two years.
Chris Picciurro:So I agree. I well, for the practitioners out there, I think one thing that that confuses people and we know the IRS is backlog. We're gonna talk before we wrap up about the your feelings on the direction of the IRS with the additional funding they're getting. I agree on on their investment in technology. Their their systems are very antiquated.
Chris Picciurro:Andrew and I both had the opportunity a few years back with the council to to meet with one of the directors of IRS in Washington DC, and and it was really eye opening. You know? They're, I almost empathized with with how they're trying to operate, in in the Flintstone. You know? It's like Fred Flintstone days.
Chris Picciurro:But, that appeals process when it when it goes to that informal hearing so, basically, the fact pattern for the practitioners is you have a client, they get audited, you don't agree with the with the revenue agent, you can't resolve it with the manager either, and it goes to that next level. That could take quite a while. So, you know, just to just so the tax professionals understand how to guide their clients on what what could be a a reasonable time frame to go from that to actually sitting down with somebody? Look, going from the time you close out as a non agreed upon case to you have a time limit to follow your appeals, right? Filing appeals and getting assigned.
Andrew Poulos:There's appeals officers in every district, every unit where there's appeals officers who are strictly work on appeals cases that get assigned to them coming out of exam, exam appeals versus collections appeals, right? Two different things. Depending on, you know, which city, which territory, which district, in a sense, you know, there's really no telling. The one we took to appeals, years ago and it was way before COVID hit, of course, now it's dropping even worse backlogs, but that effectively took, I think, a good roughly nine to ten months to get assigned. And then from there, you know, we got on the calendar.
Andrew Poulos:We had to reschedule and and whatnot. We had two meetings, in a sense with the appeals officer, But we were able to get through the process at that point once we got in with the first meeting from start to finish. I think it took probably about six or seven weeks, right? It was a pretty fast process. Appeals is not like exam.
Andrew Poulos:They're not there to drag it out, man. They want to be done with this and move along. Their goal is, you know, hazardous litigation. When you go to an appeals case, if you've never had before, the first word that's going to come out of the appeals officer's mouth is, you know, you know, purely your taxpayer's rights. You know, I can we can read them out to you if you're not aware of them, yada yada yada.
Andrew Poulos:And, of course, some hazardous litigation always comes out. That means that it's basically governments doing collateral damage, minimizing their risk. Right? They don't want a taxpayer, to go through the whole process and end up in tax court. What they know, that we should know as well is that most of the cases, if you don't agree at appeals with some you know, with the appeals officer, the taxpayer, you know, if you file the title of the case for appeals, you have tax, tax court petition rights.
Andrew Poulos:And so very few cases actually go in front of a judge in tax court. Most of them, if you have to file a tax court petition, are probably gonna be dealing with the, or the taxpayers gonna be dealing with the, with, the attorneys, you know, for the government, for the IRS, and they'll have a case out of court. And so therefore, appeals typically their job is to try to come to a resolution that's, you know, impartial and fair for both the government and the taxpayer in a sense. They want to basically minimize the risk, doing collateral damage and just be done with it. So, you know, if you ever have doubts or you have them in difficult revenue agent on an exam case, I'm never scared.
Andrew Poulos:I tell my clients, you know, someone comes to me for representation, I tell them, listen, this is your risk based on my assessment of what this return has or doesn't have, and this is where we're at. If, you know, this is gonna be your good resolution, your mediocre resolution, mid road, and this is gonna be the very worst case. And, you know, you have appeals rights. Right? So we don't get what we want.
Andrew Poulos:You tell me what your level of satisfaction would be, what you're comfortable with. And if we don't can't reach that, then I'm gonna advise you potentially, and you're gonna make the final decision about going to appeals, and we could get a better deal on appeals. I mean, I had, a case that from a client that came to me that from a practitioner, who had prepared the case. They had done the exam, and then he was sold his practice and went to work, in in the corporate world. And so I'm applying got referred over a spot on the client's day, and And it was a real estate.
Andrew Poulos:You you like this one, Chris? It was a real, professional. Right? And then and so they had agreed on a lot of things with the agent, but the agent was effectively misallowing all of his mileage and all of his meals. And the agents said, well, you don't have a mileage log and, you know, and you can't prove all these meals on your travel.
Andrew Poulos:Right? The three things so that you have to have to have a guilt substantiation the most. And the taxpayer basically was just a principal thing. It was not the money. It was just a principle.
Andrew Poulos:He said, you know what? I've driven these files. I went to the issue, you know, trip. I did this traveling for business. Just because I didn't get a deal done doesn't mean that it's not what you're explaining.
Andrew Poulos:Thanks. And they closed out the cases as un agreed upon on those after those issues, the CPA was pretty much sole practice. Client gets referred over to me and he told him what's going on. He's like, Listen, he goes, I'll pay them money if you want. It was around $40, right?
Andrew Poulos:It was a lot of money. Right. Let's not pay you because of your fee. He goes, I owe I don't care if your fee goes, it's more than the the one I owe the car. It's just a matter of principle.
Andrew Poulos:I mean, there's a lot of taxpayers like that when they know that they're in the right. Then we filed the appeals case. Didn't charge the client a lot, man. It was just there was not much meat on the bones there, but it was a principle of it. You know?
Andrew Poulos:I I understand, and I'm a man of principle. When you're right, you're right. We filed the appeals case, and it was the appeals officer that I've worked with before. And that's what I told him from the get go. I said, listen, man.
Andrew Poulos:I said, the taxpayer asked the money. I said, you know, you're a veteran appeals officer. You know how real estate is. You can go over, and he does commercial real estate. Right?
Andrew Poulos:Land and l. He could be out sightseeing and doing, you know, sightseeing for for clients and and and and work about a deal that takes four years to develop before he ever gets paid on a deal. Right? And so would land development. And I explained to them the only nine nurse, our sales officer knew very well.
Andrew Poulos:He's like, you're absolutely right. So it's just no matter of principles. I'm gonna tell you what. Instead of putting if you're reasonable with us, I said, my client will agree. If not, I said, he's prepared to pay any amount of money to take it all the way to tax just to prove a point because these are legitimate deductions even though he may not have, the mileage log and may not have all of his receipts because it was on his old laptop, you know, that he no longer has.
Andrew Poulos:Right? Then he peels off cert basically. It was short and sweet. It was like, literally, he says to me, Andrew, he goes, tell me what would make your client happy. He goes and he goes, come back to me with a proposal.
Andrew Poulos:He's like, I'm not giving him a % of of all these expenses for the deductions without my we'll concede to something. And he's like, tell them what will make your taxpayer happy. So we'll come to a resolution because I'm not letting you go to tax court or something like this. And I went back to my client. I said, listen, man.
Andrew Poulos:This is we've got a cool appeals officer, so what do you want out of this? And so he told me what he wanted. I went a little bit higher, of course, because I already knew how the game was played. And the appeals officer, I told him, wanted, you know, 85 to 90%. He's like, listen.
Andrew Poulos:How about we agree with 70%? I said, we got nothing. We never even make face to face.
Chris Picciurro:No. That's That's that's I know. It's interesting, and we're definitely happy back on this podcast in the future to dive into some other kinda interesting things. I do but in our last segment, I do wanna ask you this question because we talked a lot about I mean, we there's a lot we need to talk about in another episode of episodes, but we've talked a lot about determining the the liability. Let's talk real briefly about paying that because a lot of times the taxpayer might not have the cash available.
Chris Picciurro:And I know that, you know, there's a lot of times they they might think they're eligible for an offer in compromise, not to dive into that too much. But can you touch on, you know, the difference in in if you owe 25,000 or 50,000 is a kind of a magic number or, over $50,000, what, in in you know, what what your advice is best
Andrew Poulos:So here's here's how I approach it. Is, you know, if we can come to a deal with the government, let's just say out of appeals, and the taxpayer doesn't have the money, right? But it's a good deal for them, meaning that, hey, we've minimized your risk, right? So, you know, you if if you have prepared this return correctly, let's say, you're a small business owner. You have prepared this return correctly, you would owe a hundred thousand dollars, I could pay.
Andrew Poulos:And we've got a deal we've cut with the government here at appeals, to minimize everyone's risk and time, and you're walking away with a $40,000 tab. You're still saving money. Right? You had so you look at it and you say, okay. You have prepared this for trunk records.
Andrew Poulos:You would have paid all this money anyway. Mhmm. Or better deal. So if you agree to it, the taxpayers will say, you know what? But, you know, Chris, I don't have this money to pay.
Andrew Poulos:All we wanna do is close out the case to where it's done, and they're not gonna continue digging and prying, and it gets worse and worse. Once we close it out, then they're gonna make the assessment, the tax assessment. They'll send you a letter with the balance due with your official assessment, then it becomes a collection case. Then we have to figure out our strategy as to how to navigate the process from there. So there's a coming out of an examination to lead as a tax professional to tax representation for you and fees that you can generate in several steps.
Andrew Poulos:Right? You got exam. I don't know whether you've included there or not or you go to appeals. You know, now there's also mediation available. And then potentially from there, a collection case if the taxpayer does has an adjustment and doesn't have all the money.
Andrew Poulos:Depending on the amount due, whether it's, you know, $10, 3 grand, a hundred thousand, 2 hundred, whatever the amount is, will determine, you know, how you proceed from there and whether the taxpayer may or may not qualify for a NOIC, which we can discuss, you know, in a future episode. Right? Everyone thinks that the government will just tell them a deal post, you know, exam or post appeals case closing in. This, that's not the case. You know, if you owe the government $30,000 and you got, man, half a million bucks of liquid assets, you're not getting anywhere in the noise.
Andrew Poulos:It's right. The government's not gonna feel sorted for you. Right? You know, so then that's just the, the reality of things. So what where how we navigate and where we go after, we close out the appeals case really is dependent on, you know, the financial situation for the taxpayer, their ability to pay or not pay, you know, assets that they may or may not have.
Andrew Poulos:Just a lot of things that it would be difficult for us in this case to sit here and, you know, podcast and and and come out fast.
Chris Picciurro:And is for for a I'll I'll end with this question, then we're gonna definitely get your contact information out there to the listeners. As far as an installment agreement, you might have mentioned this, the an automated installment agreement where you basically can go on the IRS website and apply for it, without underwriting, we'll say. Yep. What does that balance total is that 50 or 20 5 thousand?
Andrew Poulos:I think it's 50 these days. They shouldn't be. I don't get chintered at all things. And and the reason I say I changed a couple things is I've got a client that referred over that I'm working with, who has a big balance. It's not an exam, but just have a balance I couldn't pay.
Andrew Poulos:Yeah. And they're looking to to pay it and they'll be able to pay it. And, you know, before you could call prior to COVID, you could call up, you know, PPS practitioner priority line, services line, or collections for that matter if it's in collections and, request, a a hold, an extension of time to pay, right, without having to provide any information or whatnot. And that's also a lot of times strategy. If the taxpayer says, hey.
Andrew Poulos:You know, Andrew, I can pay this off in ninety a hundred and twenty days or a hundred and eighty. You know, we might the strategy might be like, okay. Let's request a hold. And then by the time that hold runs out, you know, you could try to request another hold or write it out a little bit. You know, a lot of times these strategies work.
Andrew Poulos:Long story short is, they've gone from where you can request a ninety day hold to request a hundred eighty day extension of time and pay now. Right? So Absolutely. They changed. It used to be where if 50,000 had heard, that 50,000 that that they were collections or revenue officer would, require they would require, you know, a a four thirty three a collection financial information statement.
Andrew Poulos:I heard somewhere in the grapevine, I haven't had this lately recently, but that they've upped it to a hundred grand now. Things are constantly changing. So, you know, even those of us who delve, you know, and dive into tax resolution, we always have to be, you know, up to speed because government's always changing things, especially since COVID, since that landscape, you know, changed, man. Everything has changed, in a sense. A lot of times that, you know, since then, a lot of times that helps us be able to get some mercy on our client's soul.
Andrew Poulos:Right? Put some slack here. Right? And and so, there's just so much that's that's been changed. But, you know, again, you gotta what works on one case is not gonna work for the other, but overall, you know, it's a multi step process for obstructive finish from an exam to getting that closed out with payment if there's a balance due that coming out of appeals or out of it.
Chris Picciurro:Then I want to know, and then John's gonna wrap us up here. But tax professionals, if you have a client that gets a notice and you just don't know what to do or it's getting escalated on a collections case, reach out to Andrew. I'm I'm telling you, she we he's my I I can't even put it into words. Yes. He he will he is such a great resource, practical, a lot of great experience.
Chris Picciurro:And and if you and if you're sitting here or listening or jogging and you've, walking and and you tried to call the practitioner line and you've gotten on hold for a long time and hung up on and you're getting no response from the IRS, that's when it's time to say, look. This isn't in my wheelhouse. I'm gonna bring in a specialist, and and the specialist is gonna help me out. And and not only a specialist, but an active member of our of our tax professional community.
John Tripolsky:Mhmm. And then, Andrew, just so what's before we do wrap up,
Chris Picciurro:a %, what's the best, form of communication? So what what do you prefer if somebody did have a question for you, you know, in regards to tax resolution? How could they contact you?
Andrew Poulos:Yeah. I mean, look, they can reach out on the phone. They can shoot me an email. You know, they can shoot an email out, through an inquiry on our website at the poulolosaccounting.com. P 0 u l 0 s accounting, a c c 0 u n t I n g Com.
Andrew Poulos:I'll be glad to help, right? Even whether it's just kind of just a second opinion on that someone's looking or follow tax pros looking for, doesn't necessarily mean I have to get engaged in anything. A lot of times we just bounce ideas off each other. Chris and I do that all the time. You know, he's had a couple of you have cases, you know, correspondence at Jam one time when was that?
Andrew Poulos:We were sitting in Atlanta when we were filming for my show. Before the pandemic, we're setting up a you know, having a burger and some beer, man. He's like, I got a problem. I said, what kind of problem is that? Yeah.
Andrew Poulos:I was like, let's work it out. And I told him, Jackie, what about your energy? That doesn't yeah. I wasn't telling him that. You're fragile, but in a sense, like, you know, it's just bouncing our ideas off each other.
Andrew Poulos:We all have diverse backgrounds and experiences matter a lot of times. You know? It's just for me, I'm a big believer in having relationships and friendships and professional bouncing ideas off each other. Look. Yeah.
Andrew Poulos:There's there's guys that are, you know, pros that are in fact with which way more experienced than me because they've been doing it for fifty years. You know? So and a lot of times, you know, it's just like, okay. I try to reach out or, I I I to attend these, you know, seminars to learn more. You know?
Andrew Poulos:Heck, man. You gotta educate yourself and keep up to speed. Right? Whether it's, you know, reaching out to a friend or colleague about an idea or strategy for a case, or getting an education done. I mean, I can tell you very quickly.
Andrew Poulos:I don't know if you guys wanna wrap up. But, years ago, I was at taking three day conference on specific tax resolution. And the one thing that I, you know, that we were taught, not one thing, but many things. One thing we were taught, I actually had a, collection case that that Ryan Kenny Ware was representing that we ended up basically having a bad situation with the revenue officer, kicked it out of, at collections and filed an OIC. And, OIC pretty much, the by offered specialist, AMSAA, special review in the case, Try to include business assets when it was a personal, a personal tax debt.
Andrew Poulos:And, you know, it was that one thing that we'd have learned in class, that seminar that stuck out at me. I was like, wait a minute. You know? You know, it's like LG said in the seminar that you're not allowed to do that. So I went and pulled the law.
Andrew Poulos:Okay? You know what I mean? I wrote a pulled the law. I found, you know, cited the code. I sent a nice fax over to the appeals, the office specialist.
Andrew Poulos:I said, hey, man. You know, you're basically doing something that's not kosher, that's not allowed, inappropriate. Never got an apology. Never said no. I was wrong, right, like that.
Andrew Poulos:But you know what happened in a situation like that? They the we came to a resolution on an OIC. It was a hundred and $89,000 tax debt. We resolved it for 21,000 units of change. But they because of what they were doing that they were pretty much not allowed to do really.
Andrew Poulos:Beauty authority, the offer specialist, they were trying to get almost $4,548,000 bucks out of my client. It was double the money. So that that what I'm saying is that education, those several thousand bucks I spent for those three days, more than pay for itself. Right? Because you are that without knowledge, you know, none of us can progress and be able to help taxpayers out there.
Andrew Poulos:And, you know, then you got the government that will pretty much, a lot of times, try to run all over taxpayers. There.
Chris Picciurro:So And we all we'll put all oh, I'm sorry. No. I'm sorry, Andrew. No.
Andrew Poulos:I was just gonna say, Chris, I mean, just we all yeah. Just keep yourself educated. Reach out. You know? It's there's no shame in in in partnering and, you know, working with, with with other tax pros and and your colleagues and friends out there.
Andrew Poulos:I mean, look. You know? Like I said, we met at the tax council. I didn't do a tax council. You know?
Andrew Poulos:Birth form to break friendship, and we down stuff off each other all the time. Okay. Then I've dealt with this. Yes. I have.
Andrew Poulos:Team, tell me what coach section I need to go to check. Chris saves me, you know, three hours of research when he tells me what code section to go pull and vice versa. It's just not just just the way we were.
Chris Picciurro:And it's, yeah, yes. We're gonna put Andrew's contact information in the show notes. Trust me. Having him on the show is an honor. He has been on every major television national television network.
Chris Picciurro:You're gonna be very impressed with, with with him. And, thanks again. And
Andrew Poulos:Tell him you on as always.
Chris Picciurro:Yeah. Thank you. And, Andrew,
Chris Picciurro:I love these conversations between you guys because I sit here and my brain is just working because I'm more or less on the taxpayer side. So hearing you guys conversate back and forth is so so interesting to me because I. It's funny. It's not like I'm a mediator, but I'm like, wait
John Tripolsky:a minute. If you're if you're an advocate on this side, you're you're more mostly prepared. It's like, how how is everything playing out? But my biggest
Chris Picciurro:takeaway is from something like this, again, more or less from the from a taxpayer side of things, is that it really comes down to that, you know, not just expertise, but really the relationship management side of things where, you know, somebody may receive a notice, goes into freak out mode. You never wanna go into that situation guns a blazing. Right? Like, you you've mentioned strategy and planning a ton over the, you know, past almost hour that we've talked here, and it really boils down to that. Right?
Chris Picciurro:So and everything plays together. So your experience really builds into your strategy and your planning and especially how things are continually changing. Everything's ever evolving. That's gonna change. So, really, it's not to say everybody should calm down, but just having those resources and alignment and the resources for further education, like you had mentioned as well, is really the is really what the monthly recurring revenue institute is based off.
Chris Picciurro:So it's something mostly practice management but then also just building your pool of those resources, and having them at your disposal. So as always, thank you so much for joining us. Anybody who's listening to this, again, we'll have Andrew's contact in some show notes. Andrew, you'd mentioned as well your your email or your website where anybody can contact you, so we urge everybody to do so with any of those questions. And open the darn letters.
Chris Picciurro:Let's let's leave it with that. Like, put put that on your sign. Open open the darn letters.
John Tripolsky:Hey, everybody. Thanks for hanging in with us on this episode as we really dove into those best practices for IRS representation. So, Andrew, thank you as always for joining us, my friend. Always a pleasure talking with you. Always a pleasure having you on the show.
John Tripolsky:I know listening to you and Chris go back and forth, my head starts to spin a little bit just because you guys have they've been doing this for quite a long time. Not to age you at all. It's experienced, not old at all. So I'm not far behind you guys. Although, I do have more hair than both of you put together.
John Tripolsky:Let that go on on record here between those two guys. They're better looking, but I have more hair. So, all joking aside, thank you everybody for joining us on this one. If you got those great notes that you wrote down here, get ready to implement those. That is the whole point of this podcast is to just educate fellow members of the accounting and tax profession.
John Tripolsky:So if you have any questions as always as well, feel free to reach out to the monthly recurring revenue institute team. A great way is on social media. LinkedIn, we are very active on. We're always watching that, so look us up on there. We have a great YouTube channel with some little snippet videos that Chris Picuro has put together for us.
John Tripolsky:Quick little hits on the info. So we'll keep pumping those out as well for you guys. That's free content as well. If you do have any questions and you want to email us, the best email is hello@mmrinstitute.com. I'll go ahead and edit that one out.
John Tripolsky:It's hello@mrrinstitute.com. Shoot us an email any of those questions you have. We'll be happy to respond back promptly with any answers or suggestions that we may have on our side. So until next time, everybody. Thank you again for joining us.
John Tripolsky:Thank you for helping us with this content. A lot of these ideas that we put forth on this show come from Chris's experience in the private practice world as well as teaching tax flow. If you had haven't had a chance to check out teaching tax flow, it's a great place. We have a great community built into that on Facebook, defeatingtaxes.com. Again, totally free.
John Tripolsky:You can join that group. A lot of questions flow around. So that one is a lot more on the tax payer side, but there's a lot of great topics on that as well. So until next time, everybody. Thank you again for joining us, and we will see you very soon.
Disclaimer:The content of this podcast does not constitute an offer of securities. Offerings can only be made through an offering memorandum, and you should carefully examine the risk factors and other information contained in the memorandum. The content provided is for educational purposes only. We encourage you to seek personalized investment advice from your financial professional. For all tax and legal advice, please consult your CPA or attorney.
Disclaimer:Investment advisory services are offered through Cabin Advisors, a registered investment advisor. Securities are offered through Cabin Securities, a registered broker dealer.
