For Professionals & Executives

Doctors, attorneys, executives, and other high earners carry complexity that an ordinary return does not: equity and deferred compensation, several sources of income, and the visibility that comes with a professional license. The exposure is not only financial, because professional standing is usually in the picture too.

Whiteford handles sensitive tax matters discreetly. The work is to keep a matter civil, keep it contained, and resolve it on the records that support the position rather than on the ones an examiner assembles alone.

High-income returns draw scrutiny for structural reasons. Deductions that are large relative to reported income, income reported by third parties that does not match the return, and related-party or pass-through interests are among the recurring IRS audit triggers, and these returns simply have more of those moving parts.

When an adjustment brings a penalty

An audit that ends in a tax adjustment often ends with a 20 percent accuracy-related penalty under Internal Revenue Code section 6662 attached, and on a large adjustment that is real money. The penalty is asserted routinely, but it is not automatic.

Congress built defenses into the statute, and reliance on a qualified advisor is one reason to preserve those communications from the start. Where the IRS asserts fraud instead, the question turns to intent, and both the standard and the stakes change.