Defending the Defenders of Tax Law Because your reputation deserves a winning defense!

Your PTIN (Preparer Tax Identification Number) is your license to work. When the IRS threatens denial, suspension, or revocation of a PTIN, your ability to prepare returns for compensation is at risk—and so are your clients, income, software access, and reputation. At The Walton Firm—Exclusively Defending Tax Professionals, we move quickly to stabilize operations and fight the sanction.

• Due-diligence failures & preparer penalties (IRC §§ 6694/6695, including § 6695(g) credits)
   
• EFIN suitability problems or unauthorized e-file use tied back to your PTIN
   
• Pattern issues (amended returns, ERC/EITC/CTC/HOH/AOTC anomalies)
   
• Data-security lapses (shared logins, breaches, identity-theft indicators)
   
• Failure to meet PTIN program requirements (nonrenewal, inaccurate info, unpaid user fees)
   
• Conduct concerns (misleading advertising, negotiating client refunds, conflicts)
   

• Immediate bar on compensated preparation (you can’t “borrow” a colleague’s PTIN)
   
• Collateral exposure: OPR inquiries, EFIN monitoring, bank-product and software holds
   
• Client & referral loss and reputational damage that can outlast the sanction
   

• Stop “ghost prep” risk: Do not prepare for compensation without a valid PTIN.
   
• Lock down access: Enforce MFA, end shared credentials, export user logs.
   
• Preserve records: Return packets, due-diligence checklists, e-file logs, complaints, marketing.
   
• Centralize communications: Route all contact through counsel—no off-the-cuff calls.
   
• Operational plan: Paper-file/extension scripts and client messaging to control churn.
   

1) Risk Map & Theory of the Case

• Identify the alleged violations, the data IRS will rely on, and parallel-track exposure (OPR/EFIN/CI).
   

2) Evidence Build-Out

• Due-diligence files, quality-control audits, training logs, role-based access proof, engagement letters, fee/advertising disclosures, incident/breach logs.
   

3) Positioning & Written Response

• Fact-first submission: correct the record, show standards compliance, and present remediation (policies, training, access controls) that supports no suspension or shortest duration.
   

4) Appeals & Scope Control

• Challenge defects in notice, timeliness, and penalty stacking; pursue administrative appeal where available. Keep the matter from spilling into OPR or CI.
   

5) Reinstatement & Monitoring

• If a sanction issues, implement a compliance plan that supports early reinstatement and smooth vendor/software reactivation.
   

• PTIN history/renewals; current e-file application snapshot
   
• E-file transmission logs, user access records, bank-product reports
   
• QC & due-diligence policies (EITC/CTC/HOH/AOTC checklists), file-audit results
   
• WISP/data-security artifacts (MFA, encryption, VPN, device controls)
   
• Engagement letters, fee schedules, advertising/website screenshots
   
• Complaint/incident logs and corrective-action records

When the Department of Justice (DOJ) files a civil injunction to stop you from preparing tax returns, they’re trying to shut down your livelihood—often permanently. These suits, commonly called “PTIN injunctions,” are brought in federal court under 26 U.S.C. §7407 (return preparers), §7408 (promotion of abusive arrangements), and sometimes §7402(a) (broad equitable relief). At The Walton Firm—Exclusively Defending Tax Professionals, we move fast to protect your practice, your PTIN/EFIN status, and your reputation.

• You are a “tax return preparer.”
   
• You engaged in specified conduct (e.g., willful/reckless disregard of rules, understating tax, fraudulent or deceptive practices, or promoting abusive arrangements).
   
• An injunction is necessary to prevent recurrence—sometimes they ask the court to bar you from preparing any returns at all if narrower relief is “not sufficient.”
   

We focus on breaking these elements—factually, legally, and strategically.

• High-speed timelines: TROs/preliminary injunctions can be set on days’ notice, with quick discovery.
   
• Collateral damage: OPR discipline, PTIN denial/suspension, EFIN revocation/suitability, software and bank-product holds.
   
• Publicity risk: DOJ press releases can harm referrals, partnerships, and hiring.

• Stop the bleeding: Enforce unique logins + MFA, freeze risky workflows, and halt any questionable marketing.
   
• Preserve evidence: Export e-file logs, user-access reports, client lists, fee records, refund-advance stats, QC/due-diligence checklists.
   
• Centralize communications: No off-the-cuff calls or emails to IRS/DOJ—route through counsel.
   
• Operational continuity: Prepare a paper-file/extension plan and a compliant client message.

• Hire defense counsel immediately: Early narrative control can prevent a blanket ban.

1) Rapid Risk Map & Theory of the Case
We identify exactly what DOJ is alleging (credits patterns, Schedule C issues, ERC, “cookie-cutter” deductions, etc.) and build a defense narrative that explains your process, supervision, and controls.

2) Evidence Build-Out & Expert Review
We assemble the real record: engagement letters, questionnaires, contemporaneous notes, due-diligence files, training logs, audits, and third-party verification. We often add expert analysis to rebut DOJ sampling and “pattern” claims.

3) Procedural & Substantive Challenges

• Attack sampling, statistics, and the “pattern and practice” leap.
   
• Reframe alleged willfulness as good-faith reliance, documented inquiries, or client misconduct.
   
• Challenge breadth—push for narrow, targeted relief (if any), not a lifetime ban.
   

4) Parallel-Track Control
Coordinate with OPR, PTIN/EFIN units, IRS Exam/CI, and state boards so one step doesn’t trigger another.

5) Resolution Options
If appropriate, negotiate a consent order with tight scope (e.g., specific credits or procedures), compliance undertakings, training, audits, and no admission—protecting your long-term practice. If not, we’re prepared to litigate.

• Return packets, organizers, EITC/CTC/HOH/AOTC checklists, internal file-audit logs
   
• Research memos/authority supporting positions; disclosures used when standards required
   
• User access/MFA proof; role-based permissions; e-file/bank-product reports
   
• Marketing/website/fee disclosures; scripts; client communications
   
• Training sign-offs; discipline records; Written Information Security Program (WISP)
   
• Ownership/locations consistent with your e-file application (no gaps or surprises)