GPNP TAX PROFESSIONAL DEFENSE & DUE DILIGENCE UNIT

REVIEW YOUR FILES
BEFORE YOU RESPOND.

An IRS due diligence notice demands measured, disciplined calculation. Before disclosing workpapers or entering premature dialogue, initiate a comprehensive file audit to isolate exposure, verify factual records, and establish an unassailable defensive perimeter.

Strict Confidentiality Guaranteed · Please have your IRS notice letter in hand

QUALIFYING ASSESSMENT : EXAMINATION SCOPE

ARE YOU IN THE
RIGHT PLACE?

Being identified for an IRS inquiry or due diligence audit does not substantiate that a statutory violation took place. Most initial notices represent targeted administrative sweeps designed to test documentation thresholds.

Your immediate priority is establishing the precise operational boundary of the inquiry: determining whether the examination targets individual Form 8867 workpapers, software-flagged return clusters, or institutional preparer assessment.

IRS File Matrix & Trigger Registry

9 Active Categories
Trigger 01 : Form 8867 Mandate

Due Diligence Verification Letters

Audit inquiries evaluating preparer checklist fidelity across EITC, CTC, and AOTC returns.

Trigger 02 : Form 4564 IDR

Information Document Request Issuance

Formal requests for engagement letters, interview logs, and client workpaper repositories.

Trigger 03 : Section 6695 Assessments

Preparer Penalty Inquiries

Statutory notices proposing compounding assessments for alleged due diligence non-compliance.

Trigger 04 : Form 5818 Protocol

Notice of Proposed Examination Interview

Scheduled on-site office compliance visits or administrative interviews with Revenue Agents.

Trigger 05 : PTIN / EFIN Audits

Electronic Filing Identification Reviews

Cross-matching preparer identity credentials against aggregate filing variance thresholds.

Trigger 06 : Client Cluster Flags

Statistical Anomaly Sampling

IRS algorithmic flags identifying shared Schedule C mileage or home-office deduction clusters.

Trigger 07 : Section 6694 Allegations

Unreasonable Position Scrutiny

Inquiries assessing substantial authority for client aggressive tax deduction postures.

Trigger 08 : Circular 230 Disciplinary

Office of Professional Responsibility Letters

Inquiries from OPR regarding practitioner conduct, fitness, or procedural oversight standards.

Trigger 09 : 30-Day Response Mandates

Imminent Procedural Deadlines

Expiring response windows requiring formal stay requests or scope clarification motions.

ETHICAL DEFENSE ARCHITECTURE

WE DON'T CHARGE FOR WORK
YOU MAY NEVER NEED.

Traditional representation firms routinely demand exhaustive upfront retainers designed for multi-year litigation before examining a single agency record. They bill for worst-case scenarios that rarely materialize, locking your practice into compounding overhead before clarity is ever achieved.

At GPNP, we believe capital commitment must reflect diagnostic reality. Audits and inquiries unfold along distinct evidentiary paths: many conclude decisively once primary filings are substantiated, while others warrant targeted procedural maneuvering. You are billed exclusively for the exact investigative and strategic posture your case requires—never hypothetical procedures.

Strategic Pacing Guarantee: No Phase II escalation is ever authorized or invoiced without your direct written confirmation following Phase I diagnostic findings.

Phase I / Inception Investigates the past.
Phase II / Engagement Defends the present.
Phase III / Resolution Protects the future.

ENGAGEMENT SPECIFICATION

PHASE I:
INVESTIGATION

PHASE I

PREPARER DEFENSE INVESTIGATION
& EXPOSURE ASSESSMENT

INITIAL 25 SELECTED CLIENT FILES

A deliberate, contained forensic review to quantify firm exposure before initiating broader IRS engagement. Files exceeding the initial 25-client threshold or requiring customized evidentiary reconstructions are scoped separately under Phase II representation.

Direct engagement with GPNP defense specialists. Strict client confidentiality.

DELIVERABLE 01

Form 8867 Due Diligence Audit

Forensic evaluation of your paid preparer due diligence checklist records, interview sheets, and substantiation logs across EITC, CTC, ODC, AOTC, and HOH filings to detect procedural omissions before examiner inspection.

DELIVERABLE 02

25-File Forensic Review Matrix

Line-by-line diagnostic mapping of 25 priority returns selected for heightened audit probability. Identifies missing third-party notes, Schedule C records, and client confirmation weaknesses.

DELIVERABLE 03

Three-Tier Risk Classification

Triaged severity categorisation separating defensible files, remediable files requiring retroactive documentation, and high-liability files that present statutory penalty exposure under Section 6695(g).

DELIVERABLE 04

Defense Action Briefing

A confidential executive memorandum outlining your aggregate penalty exposure, immediate file preservation protocols, and strategic options for either internal remediation or formal Phase II representation.

DEFENSE PHASE TIMELINE

FIX THE CURRENT EXAM.
STRENGTHEN THE PRACTICE.

The examination is merely the immediate breach. True professional defense resolves the current inquiry, inoculates your client base against collateral audits, and embeds institutional safeguards into everyday preparation.

PHASE I · IMMEDIATE CONTAINMENT

Investigate & Secure Initial Workpapers

Establish a secure operational perimeter the moment an exam letter arrives. We audit requested returns, index existing substantiation files, and freeze disorganized communications before examiners establish an adversarial baseline.

  • Full technical intake of questioned schedules and return years
  • Establishment of strict direct-examiner communications channel
  • Immediate risk triage to preempt premature penalty assertions
Forensic file intake and investigative case binders on dark walnut conference table
Defense strategist managing formal examiner interactions and structured tax response bundles

PHASE II · STRATEGIC DEFENSE

Manage Examiner Interaction & Halt Expansion

Step between your firm and the revenue agent. We handle all Information Document Requests (IDRs), formulate formal position memos, and contest unreasonable document demands before an inquiry snowballs into a broad preparer penalty review.

  • Direct response coordination on all Information Document Requests
  • Rigorous factual containment to prevent cross-year audit spillover
  • Formal statutory position memos refuting aggressive disallowances

PHASE III · PRACTICE FORTIFICATION

Rebuild Due Diligence Systems & Train Staff

Ensure your practice never faces unmitigated scrutiny again. We extract procedural lessons from the completed examination, overhaul client intake questionnaires, and train your staff on durable due diligence documentation standards.

  • Complete modernization of client onboarding and substantiation checklists
  • Firm-wide staff coaching on Section 6694 and 6695 compliance protocols
  • Permanent institutional workpaper repository protecting long-term enterprise value
Permanent due diligence systems and fortified practice documentation manual

INSTITUTIONAL TAX RESOLUTION INFRASTRUCTURE

YOUR CASE DOESN'T HAVE TO BE
HANDLED ALONE.

GPNP operates as a comprehensive, full-service tax resolution firm structured to navigate complex administrative hurdles and aggressive IRS enforcement postures. We do not provide fragmented advice or passive clerical processing. Our central case directors actively oversee procedural strategy, record reconstruction, and procedural containment to defend your financial baseline.

When formal statutory representation, administrative appeals, or specialized taxpayer advocacy require external statutory authority, GPNP orchestrates unified coordination with our vetted alliance of licensed Enrolled Agents (EAs), Certified Public Accountants (CPAs), and strategic tax counsel. While GPNP is not a law firm, we ensure your case is anchored by credentialed professionals with the exact credentials and jurisdictional authority your defense demands.

ENROLLED AGENTS (EA)  •  CERTIFIED PUBLIC ACCOUNTANTS (CPA)  •  STRATEGIC TAX COUNSEL

COORDINATED MULTI-DISCIPLINARY TAX RESOLUTION • STATUTORY REPRESENTATION ALLIANCES • NATIONWIDE CASE SUPPORT

MATRIX FIRST.
CASE POSITION SECOND.
RESPONSE THIRD.

URGENT NOTICE

DO YOU HAVE AN IRS RESPONSE DATE APPROACHING?

Administrative response windows are strictly enforced. Missing a formal 30-day or 60-day deadline severely impairs administrative appeal rights and escalates review posture.

  • Locate every single page, schedule, and attachment of the correspondence received.
  • Ensure notice numbers (CP2000, Letter 525, Letter 3219, etc.) are unredacted.
  • Have complete case documentation ready to transmit securely during your intake review.

PROTECT WHAT YOU BUILT.

A career spent building client trust and institutional standing should not be jeopardized by uncoordinated responses. Decisive defense protocols begin the moment documentation is submitted.

Confidential Case Review • Expedited Response Protocol • Direct Defense Strategy