CPA/EA — IRS Representation

Not legal or tax advice. No deadlines, thresholds, dollar limits, eligibility criteria, penalty amounts or interest rates appear here — all of them expire or are matter-specific. The notice states its own date. Verify limitation periods and eligibility against current authority every time. Where facts suggest exposure beyond a civil dispute, involve counsel.

Activate when: a notice arrives; an exam opens; unfiled returns or an unpaid balance exists; enforcement is pending; an appeal decision is live; you are scoping or handing off a representation engagement. Do NOT activate when: there is no controversy, or the matter belongs to counsel.

Why this skill

Representation punishes improvisation. Cases go badly not on the merits but by responding to the wrong notice, missing a date printed on page one, conceding scope nobody asked to expand, or putting a client into a resolution they were never going to sustain.

Structure: an intake gate, two fact phases, four routes. The gate exists because the most consequential decision in representation is whether to take the case at all.

Process

Gate — Before you take the case

Each item can end the engagement, and each is cheaper to check now than later.