Case Study

The Situation

A $2.3 Million Problem That Appeared Out of Nowhere

Our client — a successful San Diego business owner with multiple revenue streams — opened the mailbox one afternoon and found a CP2000 notice from the IRS proposing $2.3 million in penalties and additional tax. The IRS alleged three consecutive years of unreported income, claiming the client had systematically understated earnings from their business operations.

The client’s previous accountant looked at the notice and said, essentially, “pay it.” That’s when they called us.

The Challenge

Third-Party Reporting Errors Created a Nightmare

The core of the IRS’s case rested on information returns — 1099s and K-1s filed by third parties that didn’t match the income reported on our client’s returns. On paper, it looked damning. The IRS computer systems had flagged a $2.3M discrepancy and generated the assessment.

But here’s what the IRS didn’t know: multiple third-party filers had made reporting errors. Some had double-reported income. Others had filed 1099s for amounts that were actually non-taxable reimbursements or returns of capital. The client’s returns were correct — the third-party reporting was wrong.

The challenge was proving it. We needed to reconstruct three years of complex financial records, trace every dollar back to its source, and build an airtight case that the IRS’s own data was flawed.

Our Approach

We Went Line by Line and Built an Airtight Case

This is the kind of case that separates tax attorneys from CPAs. A CPA sees a notice and thinks about compliance. We see a notice and think about strategy.

Our team reconstructed the client’s complete financial picture across all three tax years. We pulled bank records, brokerage statements, partnership agreements, and every relevant information return. Then we cross-referenced every single reported figure against the actual underlying transactions.

What we found was exactly what we expected: a trail of third-party errors that, once documented, dismantled the IRS’s entire case. Specifically, we identified:

• A brokerage firm that double-reported $890K in proceeds on two separate 1099-Bs
• A partnership that issued a K-1 reflecting income the client had already properly reported under a different entity
• Three 1099-MISC filings for amounts that were non-taxable returns of capital, not income
• Timing differences on multiple stock transactions where the cost basis was reported incorrectly

We compiled everything into a comprehensive response package with supporting documentation for every dollar in dispute, and submitted it to the IRS Automated Underreporter Unit with a detailed narrative explaining each discrepancy.

The Outcome

Every Dollar Eliminated. Case Closed.

The IRS accepted our response in its entirety. The $2.3 million proposed assessment was reduced to zero — no additional tax, no penalties, no interest. The case was closed with a “no change” determination, as if the notice had never been issued.

Our client didn’t pay a dime more than they originally owed. And they gained something equally valuable: confidence that when the IRS comes knocking, they have a team that knows exactly how to respond.

Key Takeaways

What Business Owners Should Know About IRS Notices

If you receive a CP2000 or any IRS notice proposing additional tax, here’s what you need to understand:

• Don’t panic — and don’t just pay it. The IRS’s automated systems generate assessments based on data matching. That data is frequently wrong.
• Get a tax attorney, not just a CPA. This is a legal dispute, not a bookkeeping exercise. You need someone who thinks strategically.
• Respond within the deadline. CP2000 notices typically give you 30 to 60 days to respond — check your notice for the exact deadline. Missing that window makes everything harder.
• Document everything. The IRS responds to evidence, not arguments. Build your case on paper.