What Exactly Does That Mean?

Honestly, it means accountants and enrolled agents handling audits, protests, penalty abatement requests, summons response and enforcement, statute of limitations extensions, closing agreements and on and on – virtually all procedural nuances and niches created by the Internal Revenue Code.

Special Note:  The Collection Due Process Hearing and the Tax Court’s review of a Notice of Determination issued after the CDP Hearing have gained some traction in being considered “Tax Controversy”.  See Collection Discussion.


A good tax accounting firm can and should handle 90% of those matters unless extremely unique or until something goes side-ways.  I find the unique and the side-ways issues stimulating and more frequently than not familiar.  In most of these cases (more of an administrative prelude to litigation), I begin with a description of the applicable governing law, regulations and the Internal Revenue Manual and then a concertedly simplified narrative description of everything that happened that can be easily understood by every lay person that I know.  That standard rules out assuming a background or level of understanding by the person reviewing the matter. It also engages the client in a factual examination to assure due diligence in knowing what happen and what did not.

Clarity and simplicity in explaining the resolution of procedural and substantive tax matters build a compelling narrative to assist the taxing authorities in discharging their duties.  That must be your main concern.  Anything else really does nothing more than create road blocks, even if you can obtain judicial review, which most of the time you cannot.