Appeals may send new ERC substantiation back to Compliance, but the two-year refund-suit deadline keeps running. Here is how practitioners protect the record, the Form 907 extension, and the path to PAM... with some insider tidbits.

A taxpayer can produce thousands of pages and still reach Appeals with a thin file. Here is why missing IRS file custody changes the hazards—and what PAM should do.

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