Walton Protection Practice Counsel
Essential Counsel
For a small tax practice with 1–5 preparers. Think of this as foundational outside compliance counsel. The owner needs help establishing compliant systems, reviewing IRS correspondence, addressing EFIN/ERO and due-diligence issues, and having an attorney available before problems escalate.
· Attorney compliance consultations
· Review of IRS notices and correspondence
· EFIN/ERO compliance questions
· PTIN compliance issues
· Due-diligence procedures and Form 8867 processes
· Review of one or more basic policies/SOPs
· Engagement-letter review
· Basic preparer supervision guidance
· Annual compliance/risk assessment
· Guidance when a preparer makes a compliance mistake
· IRS site-visit preparation
· Initial guidance when the IRS contacts the firm
Executive Counsel
For a growing practice with 5–15 preparers. At this size, the owner is supervising more people and has greater exposure from preparer mistakes. This level should provide more proactive legal oversight—regular compliance reviews, policy/SOP guidance, preparer supervision strategies, risk assessments, and more access to counsel.
Everything appropriate from Essential, plus more proactive oversight:
· Scheduled attorney strategy meetings
· Quarterly compliance/risk reviews
· More extensive SOP and policy review
· Preparer onboarding/offboarding compliance guidance
· EFIN security and usage controls
· Due-diligence system review
· Sample tax-return compliance reviews
· Management guidance regarding problematic preparers
· Review of significant client complaints
· IRS correspondence strategy
· Assistance preparing responses before matters escalate
· Team compliance briefings
· Government-contact protocols
· Annual Defense Readiness Review
Elite Counsel
For larger or more complicated firms with 15–25 preparers, multiple offices, service-bureau operations, or significant ERO responsibilities. This should feel much closer to having outside general counsel: deeper compliance monitoring, return sampling, internal investigations, management consultations, team training, IRS-response planning, and priority crisis support.
Everything appropriate from Executive , with a much stronger outside-counsel component:
· Regular executive legal strategy meetings
· Higher-volume compliance sampling
· Multi-office compliance reviews
· ERO oversight and supervisory-risk reviews
· Service-bureau compliance guidance, where applicable
· Customized compliance policies
· Management and preparer training
· Privileged internal investigations
· Investigation of suspected preparer misconduct
· Fraud-risk assessments
· Document-preservation guidance
· IRS interview preparation
· IRS-CI contact protocols
· Search-warrant/emergency response planning
· Priority crisis consultation
· Assistance determining whether a preparer should be suspended or terminated
· Annual mock compliance review
Enterprise Counsel
For organizations with 25+ preparers, multiple locations/states, franchise or affiliate networks, or substantial operational complexity. This should be the highest level of ongoing legal and compliance oversight, with customized governance, recurring executive meetings, organization-wide compliance systems, training, investigations, IRS/DOJ preparedness, and high-priority attorney access.
Everything appropriate from Elite, plus:
· Dedicated outside legal counsel relationship
· Customized annual legal/compliance plan
· Regular executive/leadership meetings
· Enterprise-wide compliance governance
· Multi-state/multi-location compliance oversight
· Franchise/affiliate/ERO network risk management
· Customized preparer supervision systems
· Enterprise SOP development/review
· Escalation protocols for management
· Significant IRS correspondence management
· Internal investigations
· Management legal-risk consultation
· Organization-wide training
· Annual executive compliance assessment
· Mock IRS/DOJ response exercises
· Crisis-management planning
· Priority attorney availability for government contacts
· Coordination with cybersecurity, forensic accounting, employment counsel, insurance, and other specialists when necessary