The IRS sent a letter. The date on it matters more than the amount on it.
Examinations, penalties, and collections assistance for individuals in fashion, beauty, and art. I’m not only a lawyer; I’m also a CPA.
If This Sounds Familiar…
You have received a CP2000 notice proposing taxes on income you already reported, or on platform payouts that were primarily refunds or fees.
The IRS wants to classify your line of work, studio, or practice as a hobby, potentially disallowing the years in which you incurred losses.
You haven’t filed your taxes in several years and want to address this before the IRS files a return for you, which would report only the income it knows about and disregard your expenses.
As a result, penalties and interest have escalated, turning a one-year issue into an unmanageable balance.
You’ve received a levy notice, or the IRS has already begun garnishing money from your bank account or paycheck.
A joint return with a spouse or former spouse has now become your sole responsibility.
You were paid via a 1099 for work that resembled employment, which resulted in self-employment taxes falling on you.
The total balance is significant enough to put your passport at risk, especially since your next show is scheduled outside the country.
I work exclusively with individuals, including sole proprietors and single-member LLC owners whose business income is reported on their personal tax returns. This includes many stylists, designers, artists, and estheticians I encounter.
What I Handle
Services Offered
IRS Examinations of Individual Returns: I assist with correspondence, office, and field audits, focusing on Schedule C income and expenses.
Notice Responses: I handle CP2000 notices and other underreporter notices, math error notices, and balance-due notices.
Hobby-Loss Challenges: I support clients facing challenges regarding a line, studio, or creative practice that has incurred losses.
Penalty Relief: I provide help with first-time abatement requests for clients with a clean recent history and reasonable cause requests for others.
Collections: I guide clients through installment agreements, offers in compromise, currently not collectible status, lien and levy relief, and Collection Due Process hearings.
Unfiled Returns: I help you get back into compliance, working with your preparer or one I can refer you to.
Innocent Spouse Relief: I help clients navigate requests for innocent spouse relief.
Worker Classification: I work from the worker’s side to address classification issues, including Form SS-8 determination requests and Form 8919 when a 1099 should have been a W-2.
Trust Fund Recovery Penalty Defense: I defend against personal liability for unpaid payroll taxes through the IRS.
IRS Independent Office of Appeals: I represent clients before the Appeals Office.
Income in these industries often comes in various forms: payouts from selling platforms and booking apps, multiple 1099-NEC forms from brands or clients, gallery payments in installments, and cash from markets. The IRS matches each form received against your tax return, which can lead to mismatches and notices.
With a background as a CPA before becoming a lawyer, I read your tax return from the examiner’s perspective. I understand how the Internal Revenue Code and the IRS’s internal procedures apply to your situation. Most matters can be resolved directly with the IRS or through the Appeals Office.
How It Works
Intake and Deadline: The intake form requires the notice date and notice number first because they determine the timeline for the entire process. Be sure to upload every page of the notice.
Consultation: I offer a 45-minute Zoom consultation for $250, during which I will review the notice beforehand. By the end of the call, you will understand what the IRS is proposing or doing, your exposure, your options, and the cost associated with each option.
Power of Attorney and Transcripts: Once you decide to move forward, I will file Form 2848, which allows the IRS to communicate directly with me. Additionally, I will obtain your account, wage and income, and return transcripts. Our strategy will be based on what the IRS has on record, rather than relying on memory.
Representation: I will handle all correspondence, calls, document requests, and negotiations. If the examiner or collections officer is uncooperative, I will escalate the issue to the Appeals process.
Resolution and After-Plan: The case will conclude with a written summary detailing what was resolved, any amounts owed or not owed, and a filing and payment schedule to help you avoid future notices.
Fees
The consultation fee is $250 for a 45-minute Zoom session. Before the call, I will review your notice. By the end of the consultation, you will understand the deadline, what the IRS is proposing or doing, the potential exposure, your available options, and the associated costs for each option. The $250 fee is credited toward any engagement that begins within 14 calendar days.
For defined work, the fees are flat and are to be paid at the time of engagement:
Transcript review and written assessment (when no notice has been received or you are uncertain about the IRS’s information): $600, credited toward any engagement within 30 days.
Levy release or collection hold request: $750, credited toward a payment arrangement engaged within 30 days.
First-time penalty abatement: $600
Reasonable cause penalty abatement: $1,500
Notice response (CP2000 and similar): $1,200
Installment agreement (balance under $50,000, no financial statement required): $900
Installment agreement or currently not collectible status (with financial statement): $2,500
Collection Due Process hearing request through determination: $3,000
Innocent spouse request: $3,000
Unfiled returns, compliance plan, and coordination with your preparer: $750 (preparation fees are the responsibility of your preparer).
Correspondence examination (one year): $2,500
For larger matters, pricing is determined in phases, with each phase quoted as a flat fee before it begins:
Office or field examination: $4,500 for the first year, covering the examiner’s report; additional years are $2,000 each.
Offer in compromise: $1,000 for the financial analysis and eligibility memo; $3,000 to prepare, submit, and negotiate the offer; if the IRS rejects it and an appeal is warranted, the fee is $1,500.
Appeals (examination or collections): $3,000 for the protest and the conference.
Trust Fund Recovery Penalty defense: $4,000 through the interview and written response; appeals are charged at the appeals fee.
The IRS charges fees for certain filings, including an application fee for an offer in compromise and a setup fee for an installment agreement. These fees go to the IRS, not to me, and they are separate from my charges. I will inform you of the exact amounts before anything is filed, and the IRS may reduce or waive some of these fees for low-income taxpayers.
For fees over $2,500, you can pay in two installments: half at the time of engagement and half before I submit the filing to the IRS.
What This Does Not Cover
Business Entity Tax Matters: This includes examinations of partnerships, S corporations, and C corporations, as well as employer-side payroll tax disputes. If a payroll issue has escalated to involve you personally, this falls under the Trust Fund Recovery Penalty, which I do handle.
Tax Return Preparation and Bookkeeping: My focus is on resolving disputes; your preparer handles filing the returns. I can coordinate with your preparer and can refer you to one if you need assistance.
Tax Planning: Matters related to entity selection, retirement planning, and estate questions should be addressed by your CPA or an estate planning attorney. I can refer you if you need assistance.
Criminal Tax Matters: If a situation turns criminal, I refer it to and collaborate with defense counsel.
State and Local Tax Disputes: I do not cover these.
Start Here
Please complete the pre-screen intake form and attach every page of the notice, including any pages that appear to be boilerplate. The notice number and the date on the first page indicate what the IRS is requesting and how many days you have to respond. I will reply within two business days. If the deadline is approaching faster than that, please indicate this on the form, and I will prioritize your case.
FAQs
I run my business as a single-member LLC. Am I considered an individual for this service?
1
Yes. If the LLC’s income is reported on your personal return using Schedule C, the IRS views that return as yours, and I represent you. In contrast, partnerships and S corporations file their own returns, and those examinations fall outside this practice area.
The IRS is suggesting that your losses will be disallowed because they believe you are not operating the activity with the intent to make a profit. Determining this depends on how you managed the studio: the records you kept, whether you had a business plan, any changes you made after years of losses, the time you dedicated, and your history with similar ventures. A business that lost money for three years while you built it can still be considered a legitimate business, provided your documentation supports this.
The IRS claims my studio is a hobby. What does that mean?
2
I haven’t filed my taxes in six years. Where should I start?
3
Begin by obtaining transcripts before filing any returns. Transcripts will show what the IRS already has on file, whether it has filed a return on your behalf, and if any year is already in collections. Generally, the IRS considers you compliant once the last six years are filed, and the order in which you file them matters.
Can I just call the IRS myself?
4
Yes, you can. For small balances with no disputes, a phone call or an online payment plan may be sufficient. However, if the IRS disputes a figure you disagree with, if penalties constitute a large portion of the balance, if you can’t pay what they are asking, or if you are nearing a deadline that affects your rights, representation is crucial. In those instances, what is communicated to the IRS, and when, can significantly impact the outcome.
What is the difference between hiring you and hiring a CPA?
5
A CPA can represent you before the IRS, and many do so effectively. However, two main differences matter: Communications with an attorney are privileged in ways that communications with a tax preparer typically are not, which matters in serious cases. Additionally, an attorney can take your case to the United States Tax Court if the IRS refuses to make concessions.
Do you prepare tax returns?
6
No, I do not prepare tax returns. Your tax preparer will handle that. I coordinate with them to ensure that the returns align with the resolution strategy. If you do not have a preparer, I can refer you to one.
Will my case go to Tax Court?
7
Probably not. Most issues are resolved through examinations, collections, or at the Appeals level. Tax Court is typically reserved for cases where the IRS is wrong and refuses to concede, and where the amount in question justifies taking the case further. If you receive a notice of deficiency, you have 90 days to file a petition, and that deadline is firm. If this applies to you, please indicate so on the intake form.