A revenue officer came to your business.
Do not meet alone.
941 balances, trust fund recovery, worker classification, S corp and partnership examinations, IRS summons response, ERC exams and recapture. Enrolled Agent representation at a flat fee, quoted upfront.
Payroll tax is the one balance the IRS treats as someone else's money. Withheld income tax and the employee share of FICA are trust funds, and when the business cannot pay them the IRS assesses the trust fund portion personally against whoever it decides was responsible and willful. That assessment survives the company. A field revenue officer assigned to a payroll case has the authority to levy receivables, file liens and recommend closing the doors, and the first unaccompanied meeting is where most of the damaging admissions get made.
How we fix it.
POA before the meeting
Form 2848 filed for the entity and, where the trust fund penalty is in play, for you personally. Signed and uploaded through your secure TaxDome portal after your call with Cody. No office visit, and no waiting on a mailed packet. If a meeting or an interview is already scheduled, we reschedule it and attend.
The real numbers
Business account transcripts by quarter, every open 941 and 940, the unfiled quarters, the deposit history and the payroll records. We find out what the IRS is actually holding before we say anything.
We stand in front of it
The examiner or revenue officer goes through us. Document requests are answered in writing and in scope. You do not sit for the Form 4180 interview alone.
Resolve, then stay clean
Deposits current, quarters filed, the balance into an agreement or a hardship status. An employment tax resolution defaults instantly on the next late deposit, so the forward compliance is part of the job.
Why us for business IRS problems.
Enrolled Agent, enrolled to represent taxpayers before the IRS in all 50 states, alongside CPAs and attorneys.
Finance training: the math behind every recommendation we make.
941 balances and the trust fund recovery penalty.
Letter 1153 with Form 2751 is the IRS proposing to assess the trust fund portion against you personally, and you have 60 days from that letter to file a written protest with Appeals. Form 4180 is the responsible person interview, and the answers in it become the case — who signed checks, who decided which creditors got paid, who had authority over the deposits. Do not sit for that interview alone and do not sign the 2751 because an officer says it will simplify things. If the assessment has already gone through, it lands as a CP15B. Trust fund recovery penalty defense is $3,500, handled by an Enrolled Agent with unlimited practice rights before the IRS under Circular 230.
Worker classification, and Section 530.
The IRS looks at behavioral control, financial control and the nature of the relationship, not at what the contract calls the person. Reclassifying a crew of 1099 contractors into employees produces back employment tax, penalties and interest across open quarters. Section 530 relief can stop the reclassification entirely where you had a reasonable basis, treated the whole class of workers consistently, and filed the 1099s — which is exactly why the 1099 filing history matters so much. An employment tax examination is $5,000.
ERC examinations, disallowance and recapture.
Letter 105C is a full disallowance of the Employee Retention Credit and Letter 106C is a partial one; both start a two-year clock on a refund suit and both can be taken to IRS Appeals first. Where the credit was already paid, the IRS recaptures it through an examination of the 941-X or by assessing an erroneous refund. If a promoter prepared your claim, the substantiation you need — the suspension order, the quarterly receipts comparison, the wage allocation — is usually not in the file they gave you. We rebuild it. ERC examination defense is $4,000.
Pricing, on the page.
Published prices · Quoted in writing before any work startsHow it works: one annual fee, half paid at engagement and half before your return is filed. Everything past the package baseline is a published add-on at a fixed price, so nobody counts forms. Books, payroll and sales tax are the only monthly items, because they are the only monthly work. See the full grid and every add-on or start your intake.
One practitioner. Every file, personally led.
Cody is an Enrolled Agent with an MBA, a solo practitioner with a small support team, working out of Lakeland, Florida.
Every client engagement is led by Cody personally. The firm stays deliberately small so the work stays deliberately careful. The person who filed your return is the person who handles the IRS.
Common questions.
If yours isn't here, ask it on the intake — we read every one before the first call.
A revenue officer wants to meet at my shop. What do I do?
Call us before you agree to a date, and do not meet alone. A revenue officer on an employment tax case is collecting facts about who controls the money as much as about what is owed, and a walk-through of your premises is also an inventory of what can be levied. We file the Form 2848, reschedule through the officer, and attend with you. If document requests have already gone unanswered, the next step is usually an IRS summons on Form 2039, which compels records or testimony on a fixed return date and can also be served on your bank, your payroll provider or your customers as a third-party summons. A summons of that kind is a civil enforcement tool, not a criminal charge, and it is answered rather than ignored — ignoring it is what turns it into an enforcement action in court. Send it to us the day it arrives and we respond to it.
Can the IRS really come after me personally for the company's 941?
For the trust fund portion, yes. Withheld income tax and the employee share of FICA are held in trust, and the IRS can assess that portion personally against any person it finds was responsible for paying it and willful in not doing so. That is the trust fund recovery penalty, it survives the company closing, and more than one person can be assessed for the same money. The employer share of FICA and the penalties stay with the entity.
I got Letter 1153. How long do I have?
60 days from the date on the letter to file a written protest to Appeals, 75 if the letter was addressed outside the United States. Form 2751 enclosed with it is the agreement to the assessment — signing it ends the argument. If the deadline is close, say so when you call and we will work backwards from it.
Everyone in my trade pays 1099. Is that a defense?
Industry practice is one of the reasonable-basis tests under Section 530, and it is a real argument — but only alongside the other two conditions: you treated every worker in that class the same way, and you actually filed the 1099s. Where those three hold, Section 530 can stop the reclassification cold. Where the 1099s were never filed, it generally cannot.
My ERC claim was disallowed. Is that the end of it?
No. A Letter 105C or 106C can be protested to IRS Appeals, and the notice also starts a two-year period in which a refund suit can be brought. What decides it is substantiation: the specific government order and how it suspended your operations, or the quarterly gross receipts comparison, plus a wage allocation that does not double-count PPP wages. We rebuild that file and take it to Appeals.
My 1065 was late and the penalty is per partner.
It is, and it compounds for each month the return was late, which is how a small partnership ends up with a five-figure penalty on a return that owed nothing. It arrives as a CP162 or CP162A, and the same notice covers a late or incomplete 1120-S. First-time abatement covers it where the entity has a clean prior record, and reasonable cause covers a good share of what is left. We also see partnerships that qualify for relief under the small-partnership provisions. Send the notice.
Related
- IRS representationEvery representation fee published, handled by an Enrolled Agent.
- IRS payment plans and collectionsPayment plans, hardship status and levy releases, with the option you qualify for.
- IRS audit representationMail, office and field audits handled, so you don't meet the IRS alone.
- IRS notice responseAny notice number answered for one flat fee of $600.
Get the POA in before the meeting. Not after it.
Send the form, then pick a time. Have the letter, the last four quarters of 941s and the name of the officer or examiner ready for the call. We take it from there.
Tell us what the IRS wants from the business.
A few questions, then pick a time for a free 15-minute call with Cody. Nothing starts until you sign an engagement letter.
Prefer to talk? Call (863) 370-8115 or Book a 15-minute call.
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