IRS representation and tax resolution in Nashville

Tyrone J. Taylor founded the firm and handles its IRS representation. He has been an Enrolled Agent since 2013, which carries the same unlimited practice rights before the IRS that attorneys and CPAs hold: any taxpayer, any kind of tax matter, any IRS office. He has spent about 20 years in the tax profession, more than 13 of them as an EA, and he is a Fellow of the National Tax Practice Institute.

The old site described the practice in one sentence: “His specialty is representing taxpayers in front of the Internal Revenue Service and state tax offices.” He also founded Pro Tax Education, a continuing-education provider whose courses taught other tax professionals how to represent clients before the IRS, covering account analysis, offers, installment agreements, audits and appeals.

That background explains how a case is opened here. In the firm’s words, “Our approach begins with understanding the taxpayer’s complete situation—not simply recommending an Offer in Compromise or installment agreement before reviewing the facts.”

The IRS collects a balance in one of two places, and each runs on different rules. The Automated Collection System (ACS) is the phone-and-notice side of IRS collection. Calls to it are routed to the first available employee, so nobody owns your file and each call can start over with someone new.

A Revenue Officer is a field employee assigned to your account by name. That officer explains your rights and options, asks for a Collection Information Statement on Form 433-A or 433-B, sets dates in writing and may meet you at home or at your business. The IRS says unannounced visits are rare and that a Revenue Officer normally sends an appointment letter or calls first.

The first question Tyrone answers in any case is which of the two holds the account. An ACS file is worked by phone and by letter. A field case moves on the officer’s calendar, which is why it has its own page on representation in Revenue Officer cases.

Every case follows the same five steps, in this order, whatever the balance.

• Initial case evaluation. What the IRS problem is, whether collection action is close, and whether ACS or a Revenue Officer has the account.
• IRS authorization and account analysis. Generally a Form 2848, then the account transcripts: liabilities, assessments, penalties, filing requirements, deadlines and the collection statute expiration date (CSED).
• Financial and compliance review. Income, expenses and assets, on Form 433-A, 433-B or 433-F when the IRS requires one.
• Representation and resolution strategy. The option the numbers support, negotiated with the IRS employee assigned.
• Implementation and ongoing compliance. Future returns filed on time, estimated payments made, payroll deposits kept current and the agreement kept.

The fifth step is what the whole process is aimed at. The firm puts it plainly: “Our objective is not simply to address today’s IRS problem, but to help taxpayers understand how to avoid returning to the collection process.”

Yes. The firm lists cases over $100,000 among the IRS problems it handles, and a balance that size doesn’t by itself rule out any of the options. What changes is the route. The IRS’s online long-term payment plan is limited to $50,000 of combined tax, penalties and interest, so a larger balance generally means a full financial statement and an agreement negotiated with a person, sometimes a Revenue Officer.

The collection clock matters more at this size too. Under 26 U.S.C. § 6502 the IRS generally has ten years from assessment to collect, and each tax year has its own date. The time left on those dates shapes what an installment agreement has to cover and what an Offer in Compromise is measured against. A transcript review settles both before any proposal goes to the IRS.

Currently Not Collectible (CNC) status fits when paying anything would leave you unable to cover basic living expenses. The IRS may ask for Form 433-F, 433-A or 433-B and documents proving income and expenses before it agrees. CNC stops active collection without forgiving anything: penalties and interest keep accruing, a lien may be filed, refunds are applied to the balance and the IRS may review your finances again later.

Penalty relief is a separate request that can run alongside any of these options. First-time abatement can remove failure-to-file, failure-to-pay and failure-to-deposit penalties when the same type of return was filed on time for the prior three years with no penalties. Reasonable cause is the other route. Neither one reduces the tax itself.

Everything here is general information, and what fits your case depends on its facts.