When IRS Matters Escalate, Experience Matters
Nationwide federal tax controversy representation for audits, collections, appeals, and enforcement matters
Not all IRS matters are created equal. While many tax issues can be resolved through routine compliance or correspondence, others escalate quickly into audits, collections actions, or enforcement proceedings. When that happens, experience and strategy matter.
The Tax Controversy team at Price Kong & Co, CPAs PA (Price Kong) helps individuals and businesses navigate high-risk IRS situations with clarity and confidence. Our role is to step in when matters become complex or adversarial to guide clients through the process with a steady, strategic approach focused on protection and resolution.
Price Kong’s tax controversy practice is led by former IRS Revenue Officer Mark Sullivan, EA, and focuses exclusively on federal tax controversy and enforcement defense. Our tax controversy team understands how cases are evaluated, escalated, and resolved. This depth of specialized knowledge and experience enables them to navigate IRS procedures with precision and foresight.
Types of Tax Controversy Matters
Price Kong’s tax controversy team represent clients nationwide in a variety of tax matters, including:
- IRS audits and administrative appeals
- revenue officer assignments, tax liens, levies and seizures
- payroll tax enforcement and Trust Fund Recovery Penalties (TFRP)
- multi-year non-filer situations and high-balance tax debt cases
- litigation consulting and expert witness support in civil and criminal tax matters
Our approach emphasizes early intervention, procedural control, and clear communication at every stage of the process. We focus not only on resolving the immediate issue, but on limiting downstream exposure. Our goal is to bring structure to what can feel like an overwhelming process. We focus on clear communication, thoughtful strategy, and practical solutions tailored to the client’s specific situation.
Why Early Intervention Matters
Once an IRS case escalates, timelines compress and consequences intensify. Missed deadlines, uncoordinated responses, or missteps in communication can significantly limit available options. Early intervention often allows for more flexibility and fewer surprises.
Working with a tax controversy specialist early can help:
- avoid unnecessary enforcement actions
- protect important procedural rights
- improve the client’s position in negotiations with the IRS
- reduce the risk of matters escalating further
In many cases, we consult with clients and advisors before formal representation is required, helping assess exposure, stabilize the situation, and prevent avoidable escalation.
Experience with Higher-Risk Industries
Certain industries face heightened IRS scrutiny due to income structures, payroll complexity, or regulatory overlap. Our team has extensive experience working with clients in elevated-risk sectors, including:
- high-income and self-employed individuals
- cannabis businesses affected by IRC §280E
- construction and real estate companies
- medical, legal, and professional service firms
- transportation businesses with payroll or per diem exposure
This industry-specific insight allows us to anticipate IRS positions, identify pressure points, and tailor defensible, practical strategies.
Working in Tandem with Advisors
Tax controversy resolution often requires collaboration. Our team regularly works alongside other certified public accountants (CPAs), attorneys, and finance teams to ensure:
- clear role definition and protection of privilege
- consistent, coordinated messaging to the IRS
- preservation of long-term client and advisor relationships
Our role is to manage the strategy, communication, and procedure throughout the IRS process so trusted advisors can remain focused on planning, compliance, and overall financial and business goals.
The Bottom Line
When IRS matters escalate, they demand more than technical knowledge. They require sound judgment, procedural fluency, and experience on both sides of the table. At Price Kong, our Tax Controversy practice is built to meet that challenge head-on and help clients move forward with confidence.
____
If you, or a client, are facing an IRS audit, collections activity, payroll tax enforcement, or escalating compliance issues, early consultation can make a meaningful difference. Mark Sullivan can be reached at [email protected] or 602.776.6382.