The study and the defense should be the same document.
We defend our own work. Where FactorTax established a position, we will represent you through examination and appeal, as an add-on scoped and priced with the engagement.
Documentation written for examination reads differently.
A study built to be defended and a study built to be filed are not the same document, even when they reach the same number.
Every FactorTax deliverable carries the authority each finding rests on, because the examination is the test the work is designed for. Where we then represent the client, there is nothing to reconstruct.
Through examination and appeal.
Representation before the Internal Revenue Service through examination and appeal, under Treasury Circular 230 practitioner rights.
Representation before state taxing authorities under the applicable state practitioner rules.
Response to information document requests, drawn from the workpapers behind the original study.
Technical support to the client’s own counsel where a matter moves beyond administrative resolution.
Ours, always. Someone else’s, after we have looked.
If FactorTax built the position, we defend it. That is not in question, and it does not depend on how the examination is going. Representation is a separate scope with its own flat fee, agreed in writing before it begins, because it is work beyond the study rather than a contingency we priced into it.
Where the position was taken by someone else, we take it case by case. That is not reluctance to defend a file; it is that we will not represent a conclusion we have not verified. We read what was filed first, tell you honestly what we think of it, and then decide together. FactorTax is a specialty tax firm and does not provide legal representation.