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The IRS Created an Office of Conservation Easements. Authority Will Decide Whether It Matters.
The IRS has centralized conservation-easement work, but it has not disclosed whether the new office can direct field resources, resolve BOD conflicts, or move a 1,100-case inventory.

Heath Vo, JD, CPA
Aug 249 min read


Status 12 Is Not a Developed Record: How ERC Letter 105-C Cases Reach PAM Thin
Status 12 says an IRS examination started. It does not prove the ERC issues were developed. Letter 105-C cases can reach Appeals—and PAM—with a remarkably thin file.

Heath Vo, JD, CPA
Aug 1510 min read


ERC and Research Credit Mediation: What Makes These Cases Settle in IRS Appeals
ERC and research credit disputes are fact-heavy, document-heavy, and often difficult to resolve through position papers alone. PAM can create the focused conversation these cases need.

Heath Vo, JD, CPA
Aug 155 min read


Which IRS ADR Program Fits the Case? A Practitioner’s Jurisdiction-and-Timing Map
The useful question is not whether IRS ADR exists. It is which procedure is available in the case’s present posture—and what may be lost if it fails.

Heath Vo, JD, CPA
Aug 155 min read


IRS' PAM Program (Post Appeals Mediation Program): Is it for you?
One of the most effective — and often underutilized — tools in federal tax controversy is the IRS Post Appeals Mediation (PAM) Program. While tax disputes can sometimes feel like they are headed toward an unavoidable collision course, PAM offers taxpayers and the IRS an opportunity to step into a structured, solution-oriented environment focused on resolution rather than escalation.

Heath Vo, JD, CPA
May 115 min read


So, You Got an IRS Letter? Don't Panic - Yet.
It’s not a love letter, clever invitation to Church, or one of those letters with your name or "current resident". But it is important. Why You’re Probably Reading This- You Got an IRS Letter. . . You opened your mailbox expecting coupons, political flyers, or an HOA violation. Instead, boom: “Department of the Treasury – Internal Revenue Service.” Your blood pressure spikes. You briefly consider fleeing the country. Deep breath. Getting a letter from the IRS is not a guarant

Heath Vo, JD, CPA
Aug 4, 20254 min read


IRS Letters Demanding Back Your $1,400 Stimulus Check? Here’s What to Do
Got an IRS letter asking for your $1,400 stimulus back? Find out why, how to verify the notice, dispute errors, and protect yourself.

Michelle McIllwain
Jul 28, 20253 min read


How to Request IRS Penalty Abatement - A Guide to IRS Form 843 and IRS Penalty Relief
Quick Take on IRS Penalty Relief Got hit with IRS penalties? You might be able to get them reduced or wiped out. The official vehicle is IRS Form 843, Claim for Refund and Request for Abatement (not Form 853—common mix-up). Use it to ask the IRS to remove or refund certain penalties, interest (in limited situations), additions to tax, and specific non‑income taxes. If you’ve got a one‑time slip‑up, a legit “life happened” situation, or the IRS straight‑up messed something u

Heath Vo, JD, CPA
Jul 25, 20258 min read


The IRS Wants to Fast Track Corporate Exams: But Will These 2025–2026 Changes Actually Work?
IRS’s Large Business & International Division (LB&I) has announced sweeping changes aimed at speeding up large corporate examinations. On paper, it’s all about efficiency: less red tape, more collaboration, and faster certainty for taxpayers.

Heath Vo, JD, CPA
Jul 25, 20253 min read


How to Resolve Tax Disputes with the IRS: A Guide to Alternative Dispute Resolution (ADR) Programs
Heath Vo, JD, CPA, Founding Principal, ExFed Tax IRS Alternative Dispute Resolution (ADR) programs offer taxpayers a faster, less adversarial way to resolve tax disputes without going to court. Managed by the IRS Independent Office of Appeals, these programs use mediation and settlement strategies to help taxpayers and the IRS reach fair, mutually agreeable outcomes. Why Consider ADR for IRS Tax Disputes? If you’re under IRS examination or facing unresolved tax issues conside

Heath Vo, JD, CPA
Jun 10, 20253 min read
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