For tax attorneys · Nationwide
Numbers reconstructed by someone who has already defended them on the stand.
Forensic income reconstruction, risk analysis, and expert witness testimony — from a CPA who spent seventeen years developing these cases for the government, including those with indicators of fraud that could result in a criminal referral.
Find out whether I’m the right fit for the case.
Tell me what the case is and where it sits, and I’ll tell you plainly whether my experience is the right fit for it — including when it isn’t. My qualifications and subject-matter experience are summarized below for reference; a full CV is available on request.
Case by case
One matter at a time, scoped and quoted in writing before any work begins.
A flat fee wherever it can be scoped
A reconstruction, a risk read on a position, a hazards analysis — work with a defined shape gets a fixed number in writing. Where a matter genuinely cannot be scoped up front, it is hourly, quoted the same way and agreed before it starts.
Testimony & litigation experience
Why I hold up under cross-examination.
- Testified in court as an administrative witness under the IRS testimony-authorization process
- Trained by the IRS as a Summary Expert Witness
- Fraud development experience in both civil and criminal cases
- Coordinated with IRS Counsel on trial assistance and summons enforcement
- Developed examination issues that were subsequently appealed and / or litigated
Most experts learned this work from the outside. I learned it building the case the other way, which means I know where a reconstruction is strong and where it is soft.
Qualifications
- Credential
- Certified Public Accountant — Washington State, License #50082
- Federal service
- Seventeen years, Internal Revenue Service — Internal Revenue Agent, Small Business / Self-Employed
- Lead Revenue Agent
- Senior Revenue Agent and technical expert across the organization; issue expert; coaching and leadership of a team of Revenue Agents
- Special Enforcement Program
- The most complex examinations the IRS builds — cash-intensive businesses and civil disposition cases; lead agent on a multi-entity team audit
- Internal Revenue Agent
- Independent examinations of sole proprietorships, partnerships, fiduciaries, S‑corporations and small C‑corporations; unreported-income development; fraud referral development
- Instruction
- IRS-certified instructor — Lead Instructor, Revenue Agent Basic Training; on-the-job instructor for new agents
- Specialized training
- Summary Expert Witness · High Income–High Wealth · SEP Minimum Income Probe · Lead Revenue Agent
- Education
- B.A., Accounting — Whitworth University and Gonzaga University, Spokane
- Practice rights
- Circular 230 federal practice before the IRS in all states; CPA mobility for work outside Washington
Subject-matter specialties
- IRS examination procedures
- Risk analysis and hazards of litigation
- Income reconstruction — in-depth income methods (specific-item reconstruction as the government performs it) and indirect methods
- Adequacy of books and records, including book reconstruction that holds up under Cohan
- Non-filers
- Cases carrying fraud penalties, or indicators of fraud in a matter still being worked civilly that could turn criminal
- High-income and high-wealth individuals
- Flow-through entities
- Partnership examinations, including the BBA regime
- Basis, at-risk and passive activity issues
- Information Document Request response and interview assistance
- Reasonable-cause position development for penalties
- Appeals request preparation, including the information required by Publication 3498