Dan’s extensive experience can benefit your practice. Some value-added services Dan offers as co-counsel or a legal consultant include:

• IRS Audit Preparation: Does your client face a high-stakes audit? Before letting your client talk to the IRS, consider engaging Dan to prepare your client and your defense team for IRS questioning. Especially in high stakes cases, the IRS uses court-reported summons interviews to lock the taxpayer’s story in place. Dan can help you stage a mock IRS interview before you put your client on the record with the IRS. Dan can also help you evaluate the strengths and weaknesses of your audit defense strategy including analyzing pressure points such as the statute of limitations on assessment.

• Penalty Abatement: Are you representing a taxpayer on a high-dollar penalty abatement case? Before presenting your case to the Independent Office of Appeals, consider engaging Dan to optimize your penalty appeal.

• Compliance Path Analysis: Which path is right for your client—using the Voluntary Disclosure Practice, submitting under the Streamlined Filing Compliance Procedures, making a “quiet disclosure” by filing amended returns, or another option? Given Dan’s extensive experience with IRS compliance programs, Dan can help you analyze how the IRS might view your client’s facts and what compliance path may be optimal for your client.

• “Blowing Up the Planning”: Do you have a high-net-worth client that received extensive tax planning, perhaps with international aspects? How might the IRS view the fantastic planning put in place? Consider engaging Dan to “blow up the planning,” point out weaknesses, and consider pressure points that might be revealed on audit.

• Litigation Co-Counsel: Do you have tax experience but no litigation experience? Do you prefer the Internal Revenue Code over the Federal Rules of Evidence? Consider engaging Dan as co-counsel to try your client’s case. See Dan’s experience in tax litigation.

• Expert Witness: Dan can serve as an expert witness on various matters. Please contact him regarding your specific case.