Services
Tax Controversy & IRS Representation
for DFW Individuals and Businesses
At Parr & Ibarra CPA, Adan Ibarra represents individuals, business owners, and entities before the IRS in examinations, audits, appeals, and tax disputes throughout the Dallas–Fort Worth area and across Texas. As a licensed CPA with Circular 230 representation authority and legal education, he brings both the technical tax knowledge and the analytical framework to represent clients effectively without the billing rates of a tax attorney.
If you have received an IRS notice or believe an examination is possible, the time to engage representation is before you respond not after.
Related Articles
Insights
- All Posts
- Tax Planning
Discover tax planning for Texas business owners DFW to minimize tax liabilities. Learn strategies for optimizing federal and franchise taxes.
Discover how to choose business entity tax savings in 2026. Maximize your profits and minimize your tax burden with expert...
Discover the best investments for individuals and business owners. Learn to diversify your portfolio and align with clear financial goals.
Ways We Can Help
Tax Controversy Matters We Handle
Tax controversy work is different from tax preparation in one fundamental way: the IRS is the opposing party. Every document you provide, every statement you make, and every position you assert is subject to scrutiny. Having a representative who understands both the technical tax issues and the process of an IRS proceeding protects you from common mistakes that unrepresented taxpayers make — often without realizing it until it is too late.
Correspondence Audits
The most common type of IRS examination — conducted entirely by mail. The IRS identifies a specific item on your return and requests documentation. These audits appear straightforward but frequently expand if handled incorrectly. We manage all correspondence, prepare the response package, and communicate directly with the IRS on your behalf.
Office and Field Examinations
More comprehensive audits conducted at an IRS office or at your place of business. These typically involve multiple issues across one or more tax years and require careful preparation, organized documentation, and a clear presentation of your position. We represent you throughout the examination and attend all meetings with IRS agents.
IRS Appeals
If you disagree with the results of an examination, you have the right to appeal to the IRS Independent Office of Appeals before the matter proceeds to Tax Court. Appeals officers are required to consider the hazards of litigation in evaluating a case — meaning a well-presented position has genuine leverage. We prepare the protest, present your case to the Appeals officer, and negotiate a resolution when possible.
Penalty Abatement Requests
The IRS assesses substantial penalties for failure to file, failure to pay, and accuracy-related issues — but these penalties are not always final. First-time penalty abatement is available to taxpayers with a clean compliance history. Reasonable cause abatement is available when the taxpayer can demonstrate that circumstances beyond their control caused the failure. We evaluate your eligibility and submit formal abatement requests with supporting documentation.
Unfiled Tax Returns
Taxpayers with multiple years of unfiled returns face compounding exposure — failure-to-file penalties, substitute returns filed by the IRS on unfavorable terms, and potential collection action. We bring clients into compliance by preparing and filing all outstanding returns, communicating proactively with the IRS, and establishing a resolution plan that addresses the resulting liability.
IRS Notices and CP Letters
Not every IRS notice requires a full examination response — but every notice requires a timely and accurate reply. Ignoring or mishandling an IRS notice frequently turns a manageable issue into a larger one. We review every notice, assess what is actually being requested, and prepare the appropriate response.
Trust Fund Recovery Penalty (TFRP)
Business owners and responsible parties can be held personally liable for unpaid payroll taxes under the trust fund recovery penalty — one of the most serious and commonly misunderstood IRS collection tools. We represent individuals in TFRP investigations, interview preparation, and penalty challenges.
IRS Examinations of Business Returns
S corporations, partnerships, and closely held businesses are examined on issues including reasonable compensation, classification of expenses, basis calculations, and pass-through income. We represent the entity and coordinate with owners on the personal return implications of any proposed adjustments.
We serve clients throughout Hurst, Keller, Grapevine, Addison, and the broader Dallas–Fort Worth area, and handle IRS matters for Texas clients regardless of which IRS campus or examination group has jurisdiction.
Why Having a Qualified Representative
Changes the Outcome
Most IRS examinations are not decided on the merits alone. They are decided on documentation, presentation, and the taxpayer’s or representative’s understanding of what the IRS can and cannot require.
Unrepresented taxpayers commonly provide more information than the IRS requested, agree to extend the statute of limitations without understanding the consequences, accept proposed adjustments without realizing they have the right to challenge them, and miss the window to request Appeals consideration.
A licensed CPA with Circular 230 authority changes each of those outcomes. We know what documentation is responsive to the specific request, whether to extend or resist a statute extension, how to evaluate a proposed adjustment, and when and how to escalate to Appeals.
Adan Ibarra’s legal education reinforces each of these skills with an understanding of procedural rights, evidentiary standards, and the IRS’s own internal guidelines — giving DFW clients a level of representation that goes beyond what a general-practice tax preparer can provide.
CPA Representation Authority Before the IRS
Under IRS Circular 230, licensed CPAs are authorized to represent any taxpayer before any office of the IRS — including examinations, appeals, and collection matters. This is the same representation authority held by licensed attorneys who practice before the IRS.
Adan Ibarra holds an active Texas CPA license and is authorized to represent clients in all IRS proceedings under Circular 230. His legal education supplements that authority with an understanding of procedural and evidentiary issues that arise in complex examinations and disputes.
One important clarification: CPA Circular 230 authority covers representation before the IRS and IRS Appeals. Representation in Tax Court requires separate Tax Court admission, which is distinct from bar admission and available to CPAs. If a matter proceeds to Tax Court litigation, we coordinate with tax litigation counsel and provide the technical accounting and tax analysis that supports the legal team.
What to Expect When We Represent You
1. Notice Review and Assessment
We begin by reviewing every document you have received from the IRS — notices, examination letters, information requests, or audit reports. We assess what the IRS is actually examining, what issues are in play, and what the realistic range of outcomes looks like.
2. Document Organization
We identify the records needed to support your position and help you organize and present them in a format that responds to the IRS request accurately and completely — without volunteering information beyond what is required.
3. Representation and Communication
We communicate directly with the IRS on your behalf under a signed Power of Attorney (Form 2848). You do not deal with IRS agents directly. All requests, responses, and negotiations go through us.
4. Position Development
Where the IRS has proposed adjustments we disagree with, we develop a written position supported by the tax code, regulations, and relevant authority. We present that position clearly and defend it through the examination and, if necessary, through Appeals.
5. Resolution
We pursue the best available resolution — full concession of the proposed adjustment where the IRS position is correct, partial agreement where appropriate, and full challenge through Appeals where the facts and law support it.
Frequently Asked Questions
Knowledge Center
What is the first thing I should do when I receive an IRS notice?
Do not ignore it and do not respond without understanding what is being requested. IRS notices have deadlines — some as short as 30 days — and missing them limits your options. Contact us as soon as you receive a notice. We review the document, explain exactly what the IRS is asking, and advise you on the appropriate response before any deadline passes.
Can a CPA represent me in an IRS audit without an attorney?
Yes. Licensed CPAs are fully authorized under IRS Circular 230 to represent taxpayers in IRS examinations, audits, and appeals — the same authority attorneys have before the IRS. You do not need an attorney for most IRS matters. An attorney is typically needed only if the matter proceeds to Tax Court litigation or involves potential criminal referral, both of which are uncommon outcomes in standard civil examinations.
What is the difference between an IRS audit and an IRS examination?
The terms are used interchangeably. The IRS formally calls the process an “examination,” but taxpayers and practitioners commonly refer to it as an audit. Both describe the same thing — the IRS reviewing one or more items on your tax return and requesting documentation to verify them.
How long does an IRS examination typically take?
Correspondence audits — the most common type — typically resolve within three to six months if responded to promptly and completely. Office and field examinations are more complex and can take six months to two years depending on the number of issues, the volume of records involved, and whether the matter proceeds to Appeals. We manage the timeline and keep you informed at every stage.
What happens if I disagree with the IRS's examination findings?
You have the right to request consideration by the IRS Independent Office of Appeals before the matter becomes final. Appeals is a separate function from the examination division, and Appeals officers are required to weigh the hazards of litigation in evaluating your case — meaning a well-supported position has real leverage. We prepare the formal protest and represent you through the Appeals process.
What is the trust fund recovery penalty and who is at risk
The trust fund recovery penalty allows the IRS to hold individual business owners and responsible parties personally liable for the employee portion of unpaid payroll taxes. The penalty is dollar-for-dollar — if the business owes $50,000 in trust fund taxes, each responsible person can be assessed the full $50,000 personally. Business owners, officers, and even bookkeepers with check-signing authority have been assessed this penalty. If your business has unpaid payroll taxes, this is a serious and urgent issue that requires immediate attention.
Contact Us
Ready to Work With a CPA Who Knows Your Full Picture?
Parr & Ibarra CPA serves individuals and businesses throughout Hurst, Keller, Grapevine, Addison, and the broader DFW area. If you have received an IRS notice or are facing an examination, contact us before you respond.
