IRS Tax Resolution & Appeals - Senior Enrolled Agent / Tax Attorney
hace 10 días
Dallas
Job Description Senior Enrolled Agent / Tax Attorney — IRS Tax Resolution & Appeals TaxWave | Full-Time Annual Base Salary: $80,000–$150,000 (plus Potential Performance Bonuses) Initially Hybrid | Transitioning to Fully In-Person Within the First 12 Months About the Role TaxWave is seeking a seasoned Enrolled Agent or Tax Attorney with substantial experience in IRS tax controversy, collection defense, audit representation, and complex resolution strategy for individuals and businesses. We need someone who can examine how a tax liability arose, determine whether it is correct, identify available remedies, and develop a strategy tailored to the client’s circumstances. You should be comfortable challenging unsupported IRS positions, handling difficult Revenue Officer cases, pursuing administrative appeals, securing appropriate collection holds, and recognizing opportunities that routine case processing may overlook. This is a senior technical position requiring at least seven years of directly relevant experience; ten or more years is strongly preferred. Tax preparation, general accounting, or routine installment agreement, CNC, and OIC processing alone does not meet the requirements. What You Will Do Develop and Execute Individualized Tax Strategies • Independently evaluate individual and business tax matters from initial investigation through resolution., • Analyze returns, account transcripts, examination reports, notices, financial records, prior representation, and collection history., • Determine whether the client needs an assessment challenge, collection alternative, procedural correction, penalty relief, or a coordinated combination of remedies., • Develop a primary strategy, supporting rationale, and practical alternatives if the IRS rejects the initial approach., • Identify relevant exceptions, discretionary relief, specialized procedures, and supporting authority rather than relying solely on standard processing paths., • Reassess strategy as new evidence, IRS positions, financial circumstances, or deadlines change. Challenge Underlying Liabilities and Defend Tax Positions • Review the basis for assessments and identify potentially incorrect adjustments, disallowed deductions or credits, omitted payments, and calculation errors., • Handle examination responses, disputed adjustments, and audit reconsideration matters., • Evaluate amended returns, refund claims, assessment corrections, and other available remedies according to eligibility, procedural posture, and deadlines., • Develop substantive tax arguments supported by applicable law, reconstructed calculations, specialized IRS worksheets, and documentary evidence., • Address underreporter notices, substitute-for-return assessments, and discrepancies between returns, information documents, and IRS records., • Identify premature concessions, incomplete substantiation, and missed remedies in prior casework. Lead IRS Negotiations, CDP Matters, and Administrative Appeals • Represent taxpayers before Automated Collection System personnel, Revenue Officers, examination personnel, and the IRS Independent Office of Appeals., • Independently handle Collection Due Process hearings, Equivalent Hearings, Collection Appeals Program matters, and other applicable administrative appeals., • Prepare hearing requests, protests, factual narratives, financial submissions, and persuasive written arguments., • Challenge disputed income calculations, asset valuations, allowable expenses, payment terms, and enforcement decisions., • Pursue supervisory review, appropriate reconsideration, and further administrative remedies when warranted., • Understand the differences among available appeal procedures, including their deadlines, scope, collection protections, and potential avenues for judicial review. Manage Collection Protection and Urgent Enforcement Issues • Request, substantiate, negotiate, and monitor collection holds and extensions while obtaining records, addressing compliance, preparing submissions, or resolving disputed issues., • Understand the distinction between discretionary holds and applicable statutory collection restrictions., • Document hold conditions and expiration dates, fulfill commitments, and pursue timely extensions or alternative protection where justified., • Address wage and bank levies, threatened seizures, federal payment levies, and other urgent collection activity., • Evaluate lien release, withdrawal, discharge, and subordination options, including matters involving property sales or refinancing., • Assess passport certification issues and available correction or reversal procedures., • Maintain a clear action plan for cases involving immediate financial hardship or business disruption. Navigate Specialized IRS Functions and TAS • Identify the IRS function responsible for the matter and route submissions and escalation requests appropriately., • Work with Field Collection, Collection Advisory, Centralized Insolvency, specialized collection functions, and other relevant units as the case requires., • Evaluate eligibility for Taxpayer Advocate Service assistance and prepare well-supported Form 911 requests., • Present hardship, systemic delay, and procedural breakdown issues clearly, with supporting records and specific requested action., • Follow through on referrals and escalations while independently protecting applicable deadlines., • Recognize when post-Appeals issues warrant review under retained-jurisdiction procedures or another available process. Handle Advanced Individual and Business Resolution Matters • Evaluate and pursue full-pay and partial-pay installment agreements, CNC status, and Offers in Compromise., • Assess OIC grounds involving doubt as to collectibility, doubt as to liability, effective tax administration, and qualifying special circumstances., • Challenge rejected proposals and address agreement defaults, proposed terminations, and reinstatement options., • Analyze reasonable collection potential, necessary expenses, dissipated-asset issues, asset equity, and circumstances supporting departures from standard financial treatment., • Handle business and employment tax liabilities, including coordination between entity obligations and potential personal exposure., • Evaluate Trust Fund Recovery Penalty matters, including responsible-person and willfulness issues, proposed assessments, and available protest procedures., • Address ongoing filing and federal tax deposit compliance as part of a sustainable resolution., • Evaluate penalty relief, including first-time abatement, reasonable cause, and applicable statutory exceptions, as well as interest-abatement grounds where available. Protect Rights, Deadlines, and Case Integrity • Analyze assessment, collection, and refund limitation periods, including relevant suspension or extension events., • Consider how proposed filings and procedural choices affect CSEDs, collection exposure, and future remedies., • Obtain necessary administrative records through appropriate channels, including case-file access and FOIA requests when useful., • Identify payment misapplications, account-processing problems, and other discrepancies requiring correction., • Maintain accurate documentation of IRS contacts, commitments, deadlines, and next steps., • Explain options, risks, timing, and realistic expectations clearly to clients., • Recognize when bankruptcy, litigation, criminal-tax concerns, or other specialized issues require coordination with appropriately qualified counsel. Required Qualifications • Active Enrolled Agent credential or active attorney license in good standing, with authorization to practice before the IRS., • At least seven years of substantial, hands-on experience specifically in IRS tax controversy, collection defense, and taxpayer representation., • Demonstrated experience personally handling complex negotiations, CDP proceedings, administrative appeals, Revenue Officer cases, and collection holds or extensions., • Substantial experience evaluating underlying liabilities and defending disputed tax positions, in addition to negotiating collection alternatives., • Strong working knowledge of substantive federal tax law, collection procedures, financial analysis, taxpayer rights, and procedural deadlines., • Ability to research and apply the Internal Revenue Code, Treasury Regulations, relevant case law, Internal Revenue Manual guidance, and current IRS procedures., • Professional confidence challenging unsupported IRS positions and the judgment to determine when negotiation, escalation, or an alternative remedy is appropriate., • Strong written advocacy, client communication, organization, and independent case-management skills. Additional Experience We Value • Ten or more years of concentrated tax controversy and representation practice., • Prior IRS Collection, Examination, Appeals, or Counsel experience combined with demonstrated taxpayer advocacy., • Complex business, employment tax, and Trust Fund Recovery Penalty cases., • Innocent spouse, separation-of-liability, equitable relief, and injured-spouse allocation matters., • Bankruptcy-related tax analysis and coordination with insolvency counsel., • Nominee, alter-ego, transferee, wrongful-levy, or other third-party collection issues., • Identity-theft-related assessments, disputed information returns, and difficult account corrections., • State income, payroll, sales, and use tax controversy or resolution., • International information-return penalties and related relief procedures., • Tax Court admission and litigation experience., • Familiarity with IRS Logics or comparable tax-resolution case-management systems. Candidates are not expected to specialize in every additional area. They must demonstrate the judgment to identify relevant issues, research unfamiliar questions, and involve specialized counsel when necessary. Compensation and Work Arrangement Annual base salary: $80,000–$150,000. Starting salary within this range will depend on directly relevant experience, demonstrated technical skills, and the ability to independently handle complex IRS representation matters. Particular consideration will be given to substantive tax analysis, CDP and Appeals experience, collection defense, and individualized resolution strategy. Substantial prior experience is required at every point in the salary range. This position begins on a hybrid schedule combining in-office and remote work and will transition to fully in-person work within the first 12 months of employment. Applicants must be able to commute to the designated office from the start of employment and commit to the fully on-site schedule when the transition occurs. Why TaxWave This position offers substantive ownership of challenging cases and the opportunity to apply advanced technical judgment to meaningful client problems. We value thorough investigation, persuasive advocacy, practical problem-solving, and consistent follow-through. We are looking for someone who recognizes overlooked options, supports recommendations with evidence, and takes responsibility for advancing the client’s case. How to Apply Submit your résumé and a cover letter addressing: • Your active credential and years of direct IRS controversy and taxpayer representation experience., • Your personal experience with CDP hearings, administrative appeals, Revenue Officer cases, collection holds, and TAS., • An anonymized case in which you identified an overlooked remedy, challenged an incorrect assessment, or overcame an unfavorable IRS position. Explain your approach and the outcome., • Your location, earliest available start date, and ability to meet the hybrid-to-in-person requirement. Qualified candidates will participate in a practical case discussion assessing substantive tax knowledge, procedural judgment, issue identification, negotiation strategy, and independent problem-solving. Please do not submit confidential client information. TaxWave is an equal opportunity employer. \nCompany Description At TaxWave, we are revolutionizing tax resolution through technology, automation, and data-driven strategies. By integrating secure cloud-based platforms, AI-driven insights, and automated compliance tracking, we streamline complex tax challenges for individuals and businesses, delivering efficient, transparent, and customized solutions. Our tech-driven approach enhances accuracy, speed, and decision-making, ensuring clients have real-time case updates, secure collaboration portals, and seamless IRS communication. Whether resolving audits, settlements, or payment plans, TaxWave empowers clients with greater control and confidence throughout their tax journey. If you're ready to leverage innovation and expertise in a high-performance environment, TaxWave is the place for you. At TaxWave, we are revolutionizing tax resolution through technology, automation, and data-driven strategies. By integrating secure cloud-based platforms, AI-driven insights, and automated compliance tracking, we streamline complex tax challenges for individuals and businesses, delivering efficient, transparent, and customized solutions.\r\n\r\nOur tech-driven approach enhances accuracy, speed, and decision-making, ensuring clients have real-time case updates, secure collaboration portals, and seamless IRS communication. Whether resolving audits, settlements, or payment plans, TaxWave empowers clients with greater control and confidence throughout their tax journey.\r\n\r\nIf you're ready to leverage innovation and expertise in a high-performance environment, TaxWave is the place for you.
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