Preparer Compliance and Investigation Reviews

A tax preparer investigation or compliance review is a serious threat to your professional license and business. Based in Houston and serving preparers nationwide, our firm specializes in defending against IRS due diligence audits, Circular 230 investigations, and PTIN-related inquiries. We provide expert representation for Letter 6199 and 6222 responses, ensuring your record-keeping and business practices meet the highest standards of the law. Don’t face the Office of Professional Responsibility or the DOJ alone; secure aggressive defense to protect your reputation and your right to practice.

Professional Preparer Representation in Houston & Nationwide

For tax professionals, a notice from the IRS or a state taxing authority isn’t just an audit; it’s a direct challenge to your livelihood, your reputation, and your right to practice. Whether you have received a Letter 6199 for a due diligence visit or are facing a complex Circular 230 investigation, the stakes could not be higher. Whether you’ve received an inquiry, a due diligence notice, or early signs of an investigation, how you respond matters.

Operating out of Houston, our firm provides aggressive, expert representation for tax preparers nationwide. We act as the essential “buffer” between you and government investigators, ensuring that your business practices are defended and your professional credentials are protected.

Why Tax Preparers Face Audits and Investigations

The IRS and state agencies use sophisticated data-mining tools, such as the Discriminant Index Function (DIF) score, to flag patterns across multiple returns filed under the same PTIN (Preparer Tax Identification Number).

An investigation often begins when the government identifies:

Statistical Aberrations: High volumes of specific credits (EITC, CTC, AOTC) or business deductions compared to industry norms.
Due Diligence Failures: Lack of proper documentation (Form 8867) or failure to ask “probing questions” during client intake.
Client Audits: Multiple audits of your clients that reveal a consistent pattern of errors or unreported income.

Our Comprehensive Review and Defense Process

We provide a “parallel investigation” approach. Before you meet with an IRS Revenue Agent or a Criminal Investigation (CI) Special Agent, we conduct a deep-dive review of your internal systems to identify vulnerabilities.

1. Due Diligence & Record Retention Audit

The IRS requires preparers to meet four specific due diligence requirements under IRC Section 6695(g). We review your files to ensure you have:

Knowledge Documentation: Evidence of the questions you asked and the answers provided by the client.
Consistency Checks: Verification that you addressed information that appeared “incorrect, inconsistent, or incomplete.”
Three-Year Retention: Confirmation that all worksheets, checklists, and client-provided documents are stored according to federal standards.

2. Strategic Response to IRS Letters 6199 & 6222

If you receive a Letter 6199 (Visit Request) or Letter 6222 (Correspondence IDR), you typically have only 14 days to respond. We manage this communication, helping to:

Set the scope of the interview.
Organize the required 25–50 client files for review.
Prepare you for the face-to-face or telephone interview with the examiner.

3. Defending Against Circular 230 & OPR Sanctions

The Office of Professional Responsibility (OPR) can impose severe disciplinary actions, including censure, suspension, or disbarment from practicing before the IRS. We defend your adherence to Circular 230 standards, protecting your ability to represent clients in future examinations and appeals.

Mitigating Severe Consequences for Your Firm

A mishandled investigation doesn’t just result in fines; it can lead to the end of your career. Our goal is to mitigate or eliminate the following risks:

Hefty Penalties: Fines can reach $635 per violation for due diligence failures (adjusted for inflation) and tens of thousands for failure to sign returns or provide copies.
Injunctive Relief: The Department of Justice (DOJ) may seek a civil injunction to bar you from preparing returns entirely.
Criminal Exposure: If a “Special Agent” is involved, the focus shifts to potential felony charges for “willfully aiding in the preparation of a false return.”
Reputational Damage: Disciplinary actions are often published in the Internal Revenue Bulletin (IRB), making them searchable by the public and potential clients.

Why Our Houston Firm is Your Strategic Partner

We understand that an investigation is a “test of integrity” for your processes. By combining expert tax code analysis with aggressive legal advocacy, we help you communicate specific facts and circumstances to the IRS or DOJ effectively.

From our Houston office, we represent preparers across all 50 states, providing the local expertise and nationwide reach necessary to navigate both federal and state-level preparer compliance reviews.

Get in Touch

We’d love to hear from you. We’re here to answer your questions and listen to your suggestions.