§280E Risk Review
The $375 entry diagnostic — recompute the allocation and COGS, get a written findings memo, and route to the right engagement.
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Schedule III Transition Planning
Position the books for rescheduling: lock the allocation now, stage the switch to full deductibility, and review prior years within the §6511 window.
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§471-11 / §280E COGS Review
Full-absorption producer costing under §1.471-11 — more cost into COGS, defensibly, without a §263A stretch that fails on exam.
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§7602 Audit Defense & Appeals
Responding to a §280E examination: IDR control, issue-by-issue support, penalty defense, and the path to the IRS Independent Office of Appeals.
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§6672 Trust-Fund Defense
The responsible-person and willfulness case: Letter 1153, the Form 4180 interview, and the divisible-tax / Form 843 refund route.
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§6321 / §6331 Collections Relief
Stop the levy with a Collection Due Process request, then resolve: installment agreement, offer in compromise, or currently-not-collectible status.
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§6050I Cash Compliance / Form 8300
Threshold review, back-filing with reasonable cause, and a standing SOP so every $10,000 cash receipt is reported on time.
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§471(c) / Form 8275-R Return Disclosure
Taking a contested method position the right way — disclosed on Form 8275-R, documented, and filed only on informed client approval.
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