Legal Commentary & Articles

Practical guidance for taxpayers and businesses facing IRS examinations, Appeals, Tax Court proceedings, collection matters, penalties, and criminal tax investigations.

Articles are provided for general informational purposes only and do not constitute legal advice.

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Chase Sizemore, Attorney

Attorney Chase Sizemore, JD, LLM

Principal, Chase Counsel PLLC

Georgetown Tax LLM | Former KPMG Auditor

U.S. Tax Court | Columbia University Graduate Studies

National Institute for Trial Advocacy (NITA) Diploma

30+ Years of Legal Experience

Federal Tax Controversy

I Received an IRS Audit Notice. What Should I Do?

A first 48-hour decision guide for identifying the examination, reading the notice correctly, preserving the record, and deciding on representation before responding.

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When Should You Hire a Tax Attorney for an IRS Audit?

A framework for deciding whether counsel is warranted, organized around the nature of the dispute rather than the size of the number.

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Tax Attorney vs. CPA: Who Should Represent You in an IRS Dispute?

Both can represent you before the IRS. The question is what the dispute actually turns on, and whether privilege matters.

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How Much Does an IRS Tax Attorney Cost?

What drives the number, how fees are structured at each stage of a controversy, and why comparing hourly rates is usually the wrong comparison.

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How Do I Appeal an IRS Audit?

The roadmap from an examination report to the IRS Independent Office of Appeals, what a written protest must actually contain, and what happens if Appeals does not resolve the case.

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What Happens During an IRS Appeals Conference?

A procedural walkthrough of an Appeals matter, from receipt of the case through the conference to the closing agreement, and what actually distinguishes Appeals from Examination.

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What Is a 90-Day Letter From the IRS?

The statutory notice of deficiency, the petition period it starts, what the notice does and does not mean, and the documents to gather immediately.

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What Happens If You Miss the Tax Court 90-Day Deadline?

What actually occurs procedurally after a missed deficiency petition, which alternative routes exist, what each of them requires, and why none is a substitute for a timely petition.

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When Should You Hire a U.S. Tax Court Attorney?

What Tax Court representation actually consists of, stage by stage, and why trial experience is the wrong proxy for competence in a forum where most cases settle.

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Can the IRS Levy My Bank Account?

What a levy is, the notices that must precede it, the 21-day window that determines whether the money is recoverable, and what to do the day you learn of one.

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What Should I Do If IRS Criminal Investigation Contacts Me?

Why the first interview is the decision that matters, what distinguishes a criminal investigation from an examination, and where the protections you assume you have do not exist.

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What Happens During an IRS Criminal Tax Investigation?

The lifecycle of a criminal tax matter from initiation through prosecution or declination, the review layers most people do not know exist, and why early decisions can shape the case.

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How to Prepare an IRS Appeals Protest

A practitioner-focused guide to developing the factual record, preserving legal arguments, presenting authorities, and framing the hazards of litigation before the IRS Independent Office of Appeals.

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Defending Trust Fund Recovery Penalties Under IRC § 6672

An examination of personal liability for unpaid employment taxes, Fourth Circuit standards for responsibility and willfulness, IRS assessment procedures, limitations periods, payment credits, and federal court litigation.

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Appealing a Form 5472 Penalty After the IRS Denies Reasonable Cause

A practitioner-focused analysis of §6038A penalty disputes, including reasonable cause, the small-corporation rule, systemically assessed PRN 711 penalties, IRS Appeals, Collection Due Process consequences, and refund litigation.

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IRS Cryptocurrency Audit: How to Defend the Examination

A practical guide to defending an IRS cryptocurrency examination, including basis reconstruction, Form 1099-DA reporting, wallet tracing, staking and DeFi issues, penalties, statutes of limitation, and procedural defenses.

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