When Do You Need a Tax Attorney?

Andrew Bosserman15 Sep, 2026Legal

CPAs handle compliance well, but tax controversy is different. As a former IRS agent turned tax controversy attorney, I walk through the red flags that mean a business owner or their CPA should bring in an attorney, including fraud penalties of 75% on top of the underpayment, offshore accounts where willful penalties can reach 50% of the account value a year, and IRS summonses.