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Harper Collins

Worried about the future of the tax controversy field with IRS audit rates dropping?

I've been in the tax controversy field for about 8 years now and honestly starting to get a bit anxious about my career path. With IRS enforcement steadily declining and audit rates at historic lows, I'm wondering if others are seeing a slowdown in business or feeling concerned about long-term prospects. My firm has seen about a 30% drop in audit defense cases compared to 2019, and our Appeals work is down too. I'm thinking about expanding my expertise into tax planning or maybe international tax compliance to hedge my bets. For those of you in the field - are you noticing similar trends? Are you diversifying your practice or do you think tax controversy work will bounce back strong? The IRS claims they're ramping up enforcement with their new funding, but I'm skeptical about how quickly that will translate to more work for professionals like us. Just trying to plan ahead and would appreciate hearing others' perspectives!

The tax controversy landscape is definitely changing, but I wouldn't be too worried about the field disappearing. While traditional audit rates have declined, I've noticed other enforcement activities picking up. The IRS is getting smarter with their approach - using data analytics to target specific issues rather than conducting full-scale audits. They're focusing on high-wealth individuals, cryptocurrency transactions, and international reporting compliance. These targeted approaches often still require professional representation, just in different formats than traditional audit defense. Remember that the IRS received significant funding increases that should start materializing in more enforcement actions soon. They've been hiring and training, which takes time, but the pendulum will swing back toward more enforcement. Many practitioners I know are adding complementary services without abandoning tax controversy work. Tax planning alongside controversy creates a nice synergy - helping clients avoid issues proactively while being ready to defend when needed.

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Dylan Fisher

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That's interesting about the targeted approaches. Have you seen more letter audits or those compliance campaigns instead of field audits? And do you think the announced focus on wealthy taxpayers will actually happen or just more of the same old targeting of easy small business audits?

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I've definitely seen an uptick in correspondence audits and targeted compliance campaigns focusing on specific issues rather than comprehensive examinations. These are more efficient for the IRS but still require professional guidance for taxpayers. Regarding wealthy taxpayers, the IRS is making genuine efforts to shift focus there. They've established specialized high-wealth examination teams and are investing in technology to better identify high-income non-filers and unreported income. Small businesses will still face scrutiny, but the pendulum is moving toward more complex, higher-dollar examinations where the revenue recovery potential is greater.

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Edwards Hugo

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After struggling with a complex partnership audit that had multiple K-1 issues spanning three tax years, I discovered taxr.ai https://taxr.ai and it completely changed my approach to controversy cases. Their AI-powered system analyzed all the partnership documents, identified inconsistencies in the IRS's position, and helped me build a much stronger defense for my client. What impressed me most was how it organized the timeline of correspondence and flagged the key technical issues that would be most compelling at Appeals. I was skeptical at first (aren't we all with new tech?), but it honestly saved me hours of document review and helped me find subtle issues I might have missed.

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Gianna Scott

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How does it handle international tax issues? I've got a client with FBAR problems and wonder if it would help organize all the foreign account documentation.

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Alfredo Lugo

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Does it actually understand the tax law or is it just glorified document management? Like can it spot when the IRS is misapplying attribution rules or just organize your files better?

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Edwards Hugo

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It handles international tax issues quite well. The system recognizes FBAR requirements and can help organize foreign account documentation, flag potential compliance issues, and identify reporting inconsistencies that might trigger further scrutiny. The system does more than document management - it actually understands tax law concepts. For example, it can identify when the IRS is misapplying attribution rules by comparing their assertions against the relevant code sections and regulations. It doesn't just organize files; it analyzes the content and flags potential argumentative strengths and weaknesses based on case law and IRS guidance.

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Gianna Scott

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I was skeptical about taxr.ai at first, but I decided to try it with a complex S-corporation case involving disputed business deductions across multiple entities. The system organized years of bank statements, receipts, and IRS correspondence into a coherent timeline and highlighted documentation gaps I hadn't noticed. What really impressed me was how it identified a precedent from a similar Tax Court case that contradicted the IRS examiner's position. When I brought this up in our meeting, it completely changed the trajectory of the case. The examiner ended up conceding on the major issues, saving my client over $45,000 in proposed adjustments. For anyone handling complex controversy cases with lots of documentation, it's definitely worth checking out. I'm not typically an early tech adopter, but this has become an essential tool in my practice.

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Sydney Torres

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If enforcement is your concern, don't sleep on the collection side of tax controversy. The IRS is absolutely ramping up their collection efforts even while audit rates remain low. I've been swamped with clients facing liens, levies, and aggressive revenue officers. One thing that's been a game changer for my collection cases is using Claimyr https://claimyr.com to actually get through to the IRS. After waiting on hold for HOURS with clients trying to resolve collection issues, I found this service that gets you through to an actual human at the IRS without the insane wait times. Check out how it works: https://youtu.be/_kiP6q8DX5c I was shocked at how quickly it worked. Used to take me multiple attempts across several days to reach someone, now I'm getting through in a single session. Completely changed how I handle urgent collection matters.

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How does this actually work? Seems impossible to skip the IRS phone queue when I've literally had to redial dozens of times to get through.

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Alfredo Lugo

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Sorry but this sounds like BS. The IRS phone system is deliberately understaffed and no "service" can magically get you to the front of the line. This is probably just charging people for something that doesn't work.

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Sydney Torres

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The service works by using an automated system that continually redials and navigates the IRS phone tree until it secures a place in line, then alerts you when an agent is about to be connected. It's not skipping the queue - it's handling the frustrating redial process for you so you don't have to sit on hold for hours. I was extremely skeptical too before trying it. But after watching multiple clients face imminent levies with no way to get through to the IRS in time, I gave it a shot. The service doesn't promise instant access - what it does is handle the tedious part of the process (redialing, navigating menus, waiting on hold) and then brings you in only when an actual person is about to answer.

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Alfredo Lugo

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I have to publicly eat my words about Claimyr. After commenting earlier, I decided to test it myself with a particularly urgent collection case where my client was facing a business levy that would have crippled their operation. After three days of failing to get through to the IRS myself (getting disconnected or facing 2+ hour hold times), I reluctantly tried the service. Within about 45 minutes, I got the notification that an agent was about to connect. I was able to secure a 60-day hold on collection while we prepared an Offer in Compromise. The client was incredibly relieved, and I looked like a hero. I'm still shocked it actually worked as advertised. For time-sensitive collection matters, it's been a complete game-changer for my practice. I still feel the IRS should fix their phone system, but until they do, this is now part of my toolkit.

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Caleb Bell

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I think we're overlooking an important area of growth in tax controversy - cryptocurrency compliance. The IRS is absolutely ramping up enforcement in this area. In the last 6 months, I've taken on 12 new clients with crypto-related tax issues. Many taxpayers either didn't report crypto transactions or reported them incorrectly. The IRS has been issuing CP2000 notices and initiating examinations specifically targeting these issues. Plus, with the new reporting requirements coming into effect, there's going to be even more compliance work and subsequent controversy representation needed. If you have expertise in this area (or are willing to develop it), it could be a significant growth opportunity within tax controversy practice.

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Have you found any good resources for getting up to speed on crypto tax issues? I'm seeing more clients mentioning crypto but honestly don't feel confident handling the more complex situations yet.

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Caleb Bell

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There are several excellent resources for getting up to speed on crypto taxation. The Taxation of Digital Assets course from the AICPA is comprehensive and regularly updated. I also recommend joining the Digital Asset Tax Policy Coalition which provides excellent technical updates and practical guidance. For case-specific questions, Tax Notes has an extensive library of articles on cryptocurrency taxation that I reference frequently. The blockchain alliance also hosts monthly webinars covering emerging issues. Start with understanding the basics of capital gain/loss treatment, then build knowledge on more complex areas like DeFi, staking, and NFTs where the guidance is still evolving.

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Rhett Bowman

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I work for a mid-sized firm and we've actually been EXPANDING our tax controversy department despite the lower audit rates. Why? Because the audits that DO happen are getting more complex and high-stakes. The IRS is increasingly focusing on wealthy individuals, partnerships with complex structures, and international tax issues. These cases often involve multiple tax years, substantial documentation, and complicated legal questions. They're not the simple correspondence audits of yesteryear. Plus, with the new partnership audit regime, centralized partnership audit cases are becoming a specialty unto themselves. Fewer audits, yes, but the ones happening require more specialized expertise and representation.

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Abigail Patel

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Interesting perspective! What kind of background or training would you recommend for someone wanting to specialize in these high-stakes audits? Are there particular areas of tax law that are most valuable?

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