Advertise on podcast: Tax Rep Network with Eric Green

The IRS has fewer employees. Artificial intelligence is taking on a bigger role. Enforcement is becoming more targeted. And the way cases are selected, worked—and appealed—may be about to change dramatically. So what does that mean for taxpayers and the professionals who represent them? Tax Rep Network Founder Eric Green sits down with former IRS SB/SE Commissioner Darren Guillot. Now on the other side of the table, Guillot offers a rare insider’s perspective on where the IRS is headed. They dig into the impact of the dramatic reduction in the IRS workforce, why enforcement revenue matters far beyond the dollars actually collected, and how the agency may use AI and massive amounts of taxpayer data to identify the cases most worth pursuing. Guillot also explains why AI could fundamentally change IRS audits—allowing the agency to spot risk earlier, select better cases, automate routine collection work, and concentrate experienced revenue officers and agents on higher-dollar and more complex taxpayers. Is the Independent Office of Appeals really independent? Why are some cases sitting in Appeals for years only to result in a “take 15–20% or go to court” settlement? And has Appeals drifted away from what Guillot himself helped design through the Appeals Judicial Approach and Culture (AJAC) initiative? If you represent taxpayers before the IRS, this is a conversation you’ll want to hear. The IRS of the next five years may look very different from the IRS you know today. Want to contact Darren? Email him at [email protected]

IRS Letter 11 is one notice you—and your client—cannot afford to ignore. In this episode of the Tax Rep Network Podcast, Attorney Eric Green breaks down exactly what to do when a client receives an IRS Letter 11, the Final Notice of Intent to Levy and Notice of Your Right to a Collection Due Process Hearing. With automated IRS enforcement ramping up, understanding this notice—and acting before the deadline—is critical. Eric walks through the 30-day deadline for requesting a Collection Due Process (CDP) hearing, how to properly file Form 12153, and why being able to prove timely filing matters. He also explains what happens if the 30-day deadline is missed and when an Equivalent Hearing may still be available. You’ll also learn why taxpayer compliance is essential, what to request on Form 12153 when you haven’t yet determined the best resolution strategy, and how to prepare for Appeals. Eric explains the practical differences between Forms 433-A, 433-F, and 433-H, including which financial statement to use when dealing with ACS. Letter 11 means the clock is running. This episode gives tax professionals a practical roadmap for protecting their clients from levies, preserving appeal rights, and moving the case toward resolution. The same procedures generally apply to CP90 and Letter 1058. Want to master IRS representation and build your tax resolution practice? Visit Tax Rep Network and join the growing community of tax professionals mastering IRS representation: https://TaxRepLLC.com If you're ready to stop piecing the finances together and have complete control over your money coming in and going out, check out bill.com. Turn sales tax complexity into a new revenue opportunity for your firm. Visit Zamp.com to see how. Stop referring IRS problems—and the revenue that comes with them—away. Join TRN Essentials for just $37/month and start building IRS representation today. https://taxrepnetwork.com/essential

What separates the tax professionals who struggle to find clients from those who seem to attract them effortlessly? In this episode of the Tax Rep Network Podcast, Eric Green sits down with Gabe McManus of Influential Advisor Media to discuss the power of authority marketing and why your message matters more than your marketing budget. Eric and Gabe explore how books, podcasts, storytelling, and strategic content can position you as the trusted expert in your market. They explain why clients buy confidence—not technical details—and how the right message can pre-sell prospective clients before they ever schedule a consultation. Whether you're building a tax representation practice, launching your own firm, or looking to grow your influence, this episode is packed with practical strategies to help you stand out, attract better clients, and communicate your value with confidence. Contact Gabe at: https://influentialadvisor.com/gabe/

Have you noticed that dealing with the IRS seems harder than ever? In this episode of the Tax Rep Network Podcast, tax attorney Eric Green explores a troubling trend he's seeing firsthand: IRS employees who don't understand their own procedures, give conflicting guidance, or simply fail to follow established rules. Is this the result of inexperienced staff, inadequate training, outdated systems, or something even bigger? Eric shares real-world examples from his practice, explains what these changes mean for tax professionals and taxpayers, and offers practical strategies for navigating an IRS that is becoming increasingly unpredictable. Whether you represent taxpayers or are dealing with the IRS yourself, this episode provides valuable insight into what's happening behind the scenes—and how to protect yourself when the rules seem to change depending on who answers the phone.

AI is changing tax and accounting software faster than most firms realize—but what does that actually mean for your practice? In this episode, Eric Green sits down with Liscio founder Chris Farrell to discuss why the next generation of technology will be better, faster, and cheaper. They explore how AI is driving down software costs, why many traditional accounting platforms are facing unprecedented competition, and what tax professionals should be looking for before renewing expensive software contracts. Chris explains why the future isn’t just artificial intelligence—it’s smarter, deterministic technology that automates repetitive work while leaving strategic tax planning and client relationships where they belong: with trusted advisors. They also discuss private equity’s push into accounting, the evolution of document management into “file intelligence,” and why firms that embrace these changes will gain a significant competitive advantage. Whether you’re evaluating practice management software, AI tools, or simply wondering where the profession is headed, this conversation offers practical insights into how tax professionals can build a more efficient, more profitable practice in the years ahead.

Kostelanetz Partner and Former Acting Assistant Attorney General for the Tax Division, Caroline Ciraolo, joins Eric Green for an insightful conversation about one of the most fascinating careers in tax controversy. Caroline shares her journey from Tax Court clerk to private practice, leading the Department of Justice Tax Division, and returning to one of the nation's premier tax controversy firms. They discuss what really happens inside DOJ, the professionalism of government attorneys, why relationships matter in the tax community, and how volunteering and getting involved can transform your career. They also explore why today's enforcement environment presents one of the greatest opportunities in years for attorneys, CPAs, and Enrolled Agents looking to build or expand a tax controversy practice. Whether you're just entering IRS representation or already handling complex cases, this episode is packed with practical career advice, leadership lessons, and behind-the-scenes insights from one of the most respected voices in tax controversy. In this episode you'll learn: • What it's really like leading the DOJ Tax Division • Common misconceptions about government tax attorneys • Why networking and professional organizations accelerate your career • How to build a successful tax controversy practice • Why today's IRS enforcement environment creates tremendous opportunity Be sure to subscribe—Part 2 with Caroline will focus exclusively on how to build and scale a thriving tax controversy practice. Want to contact Caroline? She can be found here: https://kostelanetz.com/our-people/caroline-d-ciraolo

Every day, accountants, CPAs, EAs, and tax attorneys are uploading confidential information, workflows, and years of hard-earned expertise into public AI platforms like ChatGPT and Claude. But what are they really giving away? In this episode, Eric Green sits down with AI entrepreneur Denis Mezheritskiy to discuss why generic AI tools aren't enough for professional firms—and why the future belongs to firms that build and control their own AI knowledge base. They cover: • Why public AI can expose your firm's intellectual property • The hidden risks of uploading client data into ChatGPT • The difference between generic AI and a proprietary "AI Brain" • How AI employees will transform accounting firms • Why tax professionals who embrace AI will outgrow those who don't • How the IRS is already using AI for enforcement and audits • What every accounting firm should be doing today to prepare for the next five years If you're a CPA, EA, attorney, bookkeeper, or firm owner, this episode will change the way you think about AI—and may convince you to stop training someone else's platform with your expertise. Learn more about the Tax Rep AI Brain at https://TaxRep.AI

Most tax professionals are so busy preparing returns and meeting deadlines that they never have time to uncover the advanced tax strategies their highest-value clients are looking for. In this episode, Eric Green sits down with tax strategist Mark Myers to discuss how CPAs, EAs, and tax attorneys can deliver dramatically more value without adding more work to their plates. They explore overlooked planning opportunities, practical strategies for high-income business owners, and how partnering with specialists can increase client loyalty, generate referrals, and significantly boost firm value. Whether you're looking to grow your firm, better serve existing clients, or uncover new revenue opportunities, this conversation is packed with practical ideas you can put to work immediately. Want to connect with Mark Myers? https://TaxWisePartners.com

What separates successful tax and accounting firms from those that stay stuck? According to sales expert Brian Mayoral, it starts with mindset. In this episode of the Tax Rep Network Podcast, Eric Green sits down with Brian Mayoral, former Tony Robbins national sales trainer and founder of We Sell Up, to discuss the psychology of growth, overcoming fear, building scalable service offerings, and creating a sales process that doesn't depend solely on referrals. Brian shares how he went from school teacher to one of Tony Robbins' top trainers and how he now helps accounting and tax firms build predictable growth through better positioning, core offerings, and sales systems. Eric and Brian also dive into entrepreneurship, failure, confidence, AI, and why "if you can't, you must" may be the most important lesson business owners can learn. Whether you're a solo practitioner or running a multi-million-dollar firm, this conversation will challenge you to think differently about growth, sales, and what's possible for your practice. Join us for a free webinar on Tuesday June 23rd at 1:00 pm EST here: https://taxrepllc.com/20260623-blueprint Connect with Brian at https://wesellup.com #TaxRepNetwork #TaxProfessionals #TaxResolution #AccountingFirmGrowth #Entrepreneurship #Mindset #SalesTraining #TonyRobbins #BusinessGrowth #TaxPracticeManagement

Can the IRS just ignore the taxpayer's Power of Attorney (POA) and contact the taxpayer directly? No, unless specific criteria are met. In this week's episode, Eric Green discusses why that threat from the IRS employee is probably empty, and what to do if they do in case they bypass you and go directly to your client.

In this episode of the Tax Rep Network Podcast, host Eric Green sits down with former IRS Office of Fraud Enforcement advisor Esther Robinson for an inside look at how civil tax audits can turn into criminal investigations. From fraud development and civil fraud penalties to IRS Criminal Investigation referrals and real-world case stories, Eric and Esther break down what tax professionals need to know when dealing with potential fraud issues. They discuss the role of the IRS Office of Fraud Enforcement, the warning signs examiners look for, why some cases become criminal while others stay civil, and the costly consequences taxpayers face when crossing the line. Packed with practical insights, behind-the-scenes IRS procedures, and war stories from the field, this episode is a must-listen for CPAs, EAs, attorneys, and anyone handling IRS controversy work. Join us for the webinar covering this in-depth on June 4th by registering here: https://taxrepllc.com/20260604-fraud/ Want to connect with Esther? Contact her at: [email protected]. If you're ready to stop piecing the finances together and have complete control over your money coming in and going out, check out bill.com. Turn sales tax complexity into a new revenue opportunity for your firm. Visit Zamp.com to see how. Stop referring IRS problems—and the revenue that comes with them—away. Join TRN Essentials for just $37/month and start building IRS representation today. https://taxrepnetwork.com/essential

In Part 2 of this deep-dive series, Eric Green is joined again by former U.S. Department of Justice Tax Division attorney John Mulcahy for an unfiltered look at what really happens behind the scenes in a criminal tax case. This episode pulls back the curtain on the critical decision-making process inside the government—from how cases are reviewed and approved for prosecution to the high bar prosecutors must meet under the “reasonable probability of conviction” standard. John walks through what happens when IRS agents submit a case, how DOJ attorneys analyze evidence, and why some cases get sent back for further development before charges are ever filed. Eric and John also tackle one of the most important (and misunderstood) opportunities for defense attorneys: the pre-charging conference with the DOJ. They explain why these meetings matter, how they can change the trajectory of a case, and what prosecutors are really looking for before deciding whether to move forward with criminal charges. The conversation then shifts to strategy—covering proffers, reverse proffers, and how both sides use these tools to either build or defend a case. You’ll hear real-world examples of how these interactions play out, including when they lead to declined prosecutions… and when they don’t. Finally, the episode explores the realities of sentencing, restitution, and negotiation dynamics—breaking down how numbers drive outcomes, why simplicity matters in front of a jury, and how acceptance of responsibility can significantly impact a client’s future. Whether you’re a tax professional, attorney, or advisor, this episode delivers practical insight into navigating criminal exposure, advising clients effectively, and understanding how the government thinks at every stage of a case. If you haven’t listened to Part 1 yet, start there—this is a continuation you won’t want to miss. Want to contact John? Email him at: [email protected].

What really happens when a tax case goes criminal? In this episode of the Tax Rep Network Podcast, host Eric Green sits down with former federal prosecutor John Mulcahy—now in private practice at Nixon Peabody—to pull back the curtain on how criminal tax cases are built, reviewed, and prosecuted. Drawing on over a decade of experience at the U.S. Attorney’s Office and the DOJ’s tax division, John walks through the lifecycle of a criminal tax case—from initial IRS investigation to DOJ review, grand jury proceedings, and ultimately, prosecution decisions. Along the way, he explains why the DOJ still plays a critical gatekeeping role and how consistency in tax enforcement is maintained nationwide. But this conversation goes beyond process. Eric and John dig into the real-world dynamics that shape outcomes: the discretion of Assistant U.S. Attorneys, the strategic decisions behind charging (or declining) a case, and the often misunderstood role of “willfulness” in tax crimes. Through candid stories and behind-the-scenes insights, they highlight how cases can turn on a single issue—especially intent—and why listening closely to clients can make or break a defense. Now on the defense side, John also shares what it’s like transitioning from prosecutor to advocate—working with clients in crisis, navigating complex facts, and seeing firsthand that every case has more than one side. If you’re a tax professional, attorney, or anyone curious about how criminal tax enforcement really works, this episode offers a rare insider perspective you won’t hear anywhere else. Want to contact John?  Email him at: [email protected] If you're ready to stop piecing the finances together and have complete control over your money coming in and going out, check out bill.com. Turn sales tax complexity into a new revenue opportunity for your firm. Visit Zamp.com to see how. Stop referring IRS problems—and the revenue that comes with them—away. Join TRN Essentials for just $37/month and start building IRS representation today. https://taxrepnetwork.com/essential

In this inspiring and practical episode, Eric Green sits down with tax attorney and educator Beverly Winstead to break down one of the most overwhelming challenges taxpayers face: getting out of tax debt—and staying out. Drawing from her book Get Out of Tax Debt Now, Beverly shares not only the technical steps to deal with the IRS, but also the mindset shifts that are critical to overcoming financial struggles. From her journey as a student-athlete to running the Low Income Taxpayer Clinic at the University of Maryland, Beverly brings a unique blend of personal experience, resilience, and professional expertise to the conversation. This episode goes beyond tax strategy—it’s about real-life challenges and real solutions. Beverly opens up about her own financial hardships, including student loan debt and facing foreclosure, and how those experiences shaped her mission to help others navigate the system with clarity and confidence. Whether you’re a taxpayer feeling overwhelmed or a practitioner looking for a better way to guide clients, this episode delivers clear, actionable advice without the jargon. If you’re tired of ignoring the problem and ready to take control, this conversation is your starting point. Grab a copy of Beverly’s new book here! Want to contact Beverly?  Email her at: [email protected]. If you're ready to stop piecing the finances together and have complete control over your money coming in and going out, check out bill.com. Turn sales tax complexity into a new revenue opportunity for your firm. Visit Zamp.com to see how. Stop referring IRS problems—and the revenue that comes with them—away. Join TRN Essentials for just $37/month and start building IRS representation today. https://taxrepnetwork.com/essential

A recent court ruling could unlock major refunds for taxpayers – but the clock is ticking. In this episode, Eric Green sits down with Kenny Dettman to break down the massive implications of the Kwong and Abdo decisions, as well as why they could mean widespread penalty and interest abatements tied to the COVID-era IRS shutdown period.   At the center of it all? The IRS’s handling of IRC §7508A during the federally declared disaster window from 2020 through mid-2023. According to recent rulings, deadlines may have been suspended, potentially invalidating penalties and interest assessed during that time. But here’s the catch: the deadline to act is July 11, 2026. They also discuss scalable solutions, including new tools designed to automate transcript retrieval, calculations, and filings, giving both taxpayers and practitioners a way to act before time runs out.   Whether you’re a tax professional or a taxpayer, this is one of those “don’t miss it” moments. Because come July 12… the opportunity may be gone for good. Tune in now and make sure you’re not the one saying, “Why didn’t I know about this?”   Check out Penalty Back and see what you can recover here: https://trn.penaltyback.com/ If you're ready to stop piecing the finances together and have complete control over your money coming in and going out, check out bill.com. Turn sales tax complexity into a new revenue opportunity for your firm. Visit Zamp.com to see how. Stop referring IRS problems—and the revenue that comes with them—away. Join TRN Essentials for just $37/month and start building IRS representation today. https://taxrepnetwork.com/essential