HI, thanks for reviewing..
Seeking an experienced U.S. tax attorney for an initial paid 60min or less consulting engagement to review a complex small-business tax and entity-structure situation and advise on strategy before moving forward with a larger engagement.
This is not a request for immediate filing or boilerplate compliance work. I am looking for an attorney who is comfortable advising on strategy, risk, and options, and who works collaboratively with clients to reach practical outcomes.
High-level background:
- Multiple LLCs under 2 holding entities (One for operating, another investments/real estate)
- One S-Corp election; others default LLCs
- Prior CPA consolidated several entities for bookkeeping/tax reporting due to limited activity and mixed transactions (concerns with this)
- Prior-year returns prepared but not yet signed
- Significant penalties assessed due to delayed filings caused from accountant bookkeeping/preparing delay, compounded by secondary matter below.
- I retain 100% disabled veteran status
- Desire to reduce overall exposure lawfully through proper classification, amendments where appropriate, and IRS relief programs
- Secondary Matter: Certain transactions under one operating LLC are now disputed and under review (I'm a victim/plaintiff in the civil theft matter, with concurring federal involvement against defendant)
What I am looking for help with:
- Strategic review of entity structure and whether simplification or reorganization makes sense going forward
- Legal review of prior-year tax treatment and whether amendments are advisable
- Guidance on loss classification and related tax treatment (high level, not accounting entry work) as current pre-planned departure of outgoing accountant (non related to the civil theft matter) has stopped everything until Tax Attny involved.
- Strategy for penalty abatement, reasonable cause arguments, and whether an Offer in Compromise or other resolution programs are appropriate
- Advice on how to properly unwind or correct prior bookkeeping consolidation and hand off cleanly to a new CPA/bookkeeper
- Determining whether existing prepared returns should be used as-is, amended, or replaced
What this engagement is not:
- Not looking for a “file first, ask questions later” approach, hourly churn without strategy, or tax prep only.
Ideal background:
- Tax attorney with experience in:
--Small to mid-size businesses
--Multi-entity structures
--IRS controversy / penalty abatement
--Amendments and cleanup situations
-Comfortable working alongside accountants
-Clear communicator who can explain tradeoffs and risk
Looking forward to working with you, please respond with:
- Brief summary of relevant experience
- Any limitations or conflicts I should be aware of
Thank you in advance.