IRC §6694 / §6695 PENALTY DEFENSE
Protecting your license, livelihood, and reputation.
When the IRS asserts preparer penalties under IRC §6694 (understatements due to preparer conduct) or IRC §6695 (procedural and due-diligence failures), the consequences reach far beyond a dollar figure. You face OPR exposure, EFIN/PTIN risk, software and bank-product holds, and potential criminal referral if the facts suggest willfulness. At The Walton Firm—Exclusively Defending Tax Professionals—we move fast, control the record, and fight to protect your ability to practice.
OUR DEFENSE APPROACH
Early Triage & Narrative Control
- Lock down communications; we become the point of contact.
- Build a defensible timeline and theory of the case before you say a word on the merits.
Authority & Standards Analysis (the heart of §6694)
- Map each challenged position to substantial authority, reasonable basis with disclosure, or more-likely-than-not where applicable.
- Deploy ruling hierarchies (statute, regs, court decisions, revenue rulings/procedures, notices, PLRs, etc.) to re-classify alleged “unreasonable” positions.
Fact Development & Documentation
- Retrieve engagement letters, questionnaires, organizer notes, computation workpapers, memos, and contemporaneous emails.
- Show client-provided facts, reasonable inquiries, and your reliance (where appropriate).
- For §6695(g), produce due-diligence checklists, third-party verifications, residency/school/enrollment proofs, and HOH substantiation workflows.
WHY CHOOSE THE WALTON FIRM
Exclusively Defending Tax Professionals—we know the playbook on both sides.
- Authority-driven briefs that reframe §6694 allegations and dismantle §6695 assertions.
- Parallel-proceeding control (OPR/EFIN/PTIN/CI) to protect the whole practice, not just one case.
- Nationwide representation with battle-tested checklists, templates, and remediation kits.se to handle even the most complex tax situations. She has helped countless individuals and businesses save money on their taxes while staying in compliance with all applicable laws and regulations.
A preparer-penalty letter is not “just a fine.” It’s a direct threat to your practice.