The years already filed are not closed.
Where prior treatment was wrong, the correction reaches back. Phase 3 recovers what those years overstated or left unclaimed, through the mechanisms the law provides.
Recovery is a computation, not a claim.
Prior-period value sits in two places: cost that was allocated incorrectly on the contract side, and deductions never taken on the tax side.
Both are recoverable, and neither is recovered by arguing. They are recovered by computing the cumulative difference correctly and filing it on the right form, with the authority for every step on the page.
Quantify, source, file.
The prior-period population is established: which years, which assets, which cost pools, and what the correct treatment would have been.
The cumulative effect is computed asset by asset rather than estimated, with sign and spread treatment determined.
Where the correction is a change in method of accounting, it is captured as a §481(a) adjustment on Form 3115, typically under the automatic consent procedures.
Contract-side cost allocation corrections are identified and reconciled against the tax correction, so the two readings land together.
Every figure carries the authority it rests on, because a recovery that cannot be defended is not a recovery.
You choose the delivery tier.
FactorTax delivers the analysis and the filing-ready documentation, built to withstand examination. Your tax provider implements it.
FactorTax delivers the study and implements it end to end, preparing and filing the accounting-method change and signing as practitioner of record under Treasury Circular 230.
Every engagement is a single flat fee, fixed in the engagement letter before work begins. No ranges, no hourly billing, and no fee that moves with the size of the result.