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by Eric L. Green, Esq. - National Speaker and Author
Join Eric L. Green with Tax Rep Network and build your practice. Navigate the ins-and-outs of IRS Collections, Offers-in-Compromise, Reducing IRS Penalties, etc. Turn this hottest of growth areas into a revenue stream for your practice and help hundreds of people resolve their worst nightmare!
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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 opportunityBe 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 yearsIf 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-blueprintConnect 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: Esther@treestoneadvisory.com.
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: jmulcahy@nixonpeabody.com.
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: jmulcahy@nixonpeabody.com
Join Eric L. Green with Tax Rep Network and build your practice. Navigate the ins-and-outs of IRS Collections, Offers-in-Compromise, Reducing IRS Penalties, etc. Turn this hottest of growth areas into a revenue stream for your practice and help hundreds of people resolve their worst nightmare!
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