Tax Rep Network with Eric Green

IRS Letter 11 is one notice you—and your client—cannot afford to ignore.
In this episode of the Tax Rep Network Podcast, Attorney Eric Green breaks down exactly what to do when a client receives an IRS Letter 11, the Final Notice of Intent to Levy and Notice of Your Right to a Collection Due Process Hearing. With automated IRS enforcement ramping up, understanding this notice—and acting before the deadline—is critical.

Eric walks through the 30-day deadline for requesting a Collection Due Process (CDP) hearing, how to properly file Form 12153, and why being able to prove timely filing matters. He also explains what happens if the 30-day deadline is missed and when an Equivalent Hearing may still be available.
You’ll also learn why taxpayer compliance is essential, what to request on Form 12153 when you haven’t yet determined the best resolution strategy, and how to prepare for Appeals. Eric explains the practical differences between Forms 433-A, 433-F, and 433-H, including which financial statement to use when dealing with ACS.

Letter 11 means the clock is running. This episode gives tax professionals a practical roadmap for protecting their clients from levies, preserving appeal rights, and moving the case toward resolution.
The same procedures generally apply to CP90 and Letter 1058.

Want to master IRS representation and build your tax resolution practice? Visit Tax Rep Network and join the growing community of tax professionals mastering IRS representation: https://TaxRepLLC.com

What separates the tax professionals who struggle to find clients from those who seem to attract them effortlessly? In this episode of the Tax Rep Network Podcast, Eric Green sits down with Gabe McManus of Influential Advisor Media to discuss the power of authority marketing and why your message matters more than your marketing budget.

Eric and Gabe explore how books, podcasts, storytelling, and strategic content can position you as the trusted expert in your market. They explain why clients buy confidence—not technical details—and how the right message can pre-sell prospective clients before they ever schedule a consultation.

Whether you're building a tax representation practice, launching your own firm, or looking to grow your influence, this episode is packed with practical strategies to help you stand out, attract better clients, and communicate your value with confidence.

Contact Gabe at: https://influentialadvisor.com/gabe/

Have you noticed that dealing with the IRS seems harder than ever? In this episode of the Tax Rep Network Podcast, tax attorney Eric Green explores a troubling trend he's seeing firsthand: IRS employees who don't understand their own procedures, give conflicting guidance, or simply fail to follow established rules.

Is this the result of inexperienced staff, inadequate training, outdated systems, or something even bigger? Eric shares real-world examples from his practice, explains what these changes mean for tax professionals and taxpayers, and offers practical strategies for navigating an IRS that is becoming increasingly unpredictable.

Whether you represent taxpayers or are dealing with the IRS yourself, this episode provides valuable insight into what's happening behind the scenes—and how to protect yourself when the rules seem to change depending on who answers the phone.

AI is changing tax and accounting software faster than most firms realize—but what does that actually mean for your practice? In this episode, Eric Green sits down with Liscio founder Chris Farrell to discuss why the next generation of technology will be better, faster, and cheaper. They explore how AI is driving down software costs, why many traditional accounting platforms are facing unprecedented competition, and what tax professionals should be looking for before renewing expensive software contracts.

Chris explains why the future isn’t just artificial intelligence—it’s smarter, deterministic technology that automates repetitive work while leaving strategic tax planning and client relationships where they belong: with trusted advisors. They also discuss private equity’s push into accounting, the evolution of document management into “file intelligence,” and why firms that embrace these changes will gain a significant competitive advantage.

Whether you’re evaluating practice management software, AI tools, or simply wondering where the profession is headed, this conversation offers practical insights into how tax professionals can build a more efficient, more profitable practice in the years ahead.

Kostelanetz Partner and Former Acting Assistant Attorney General for the Tax Division, Caroline Ciraolo, joins Eric Green for an insightful conversation about one of the most fascinating careers in tax controversy. Caroline shares her journey from Tax Court clerk to private practice, leading the Department of Justice Tax Division, and returning to one of the nation's premier tax controversy firms.
They discuss what really happens inside DOJ, the professionalism of government attorneys, why relationships matter in the tax community, and how volunteering and getting involved can transform your career. They also explore why today's enforcement environment presents one of the greatest opportunities in years for attorneys, CPAs, and Enrolled Agents looking to build or expand a tax controversy practice.
Whether you're just entering IRS representation or already handling complex cases, this episode is packed with practical career advice, leadership lessons, and behind-the-scenes insights from one of the most respected voices in tax controversy.

In this episode you'll learn:
• What it's really like leading the DOJ Tax Division
• Common misconceptions about government tax attorneys
• Why networking and professional organizations accelerate your career
• How to build a successful tax controversy practice
• Why today's IRS enforcement environment creates tremendous opportunity

Be sure to subscribe—Part 2 with Caroline will focus exclusively on how to build and scale a thriving tax controversy practice.

Want to contact Caroline? She can be found here: https://kostelanetz.com/our-people/caroline-d-ciraolo