AuthorW. Patrick Cantrell
My reason for writing this book has to do with perceived necessity. I was
unaware of a practical reference book delineating rules for dealing with real-
life problems faced by a typical practitioner whose clients have confronted
otherwise unsolvable IRS problems. The IRS is a huge bureaucracy with
approximately one hundred thousand employees across the United States and
in foreign countries. The powers of these employees rival those of the most
despotic governments in history. The disparity of power between IRS employ-
ees and the typical taxpayer is my raison d’être.
This book is intended as a reference manual to be used by the casual
practitioner of tax procedure as well as by serious scholars. Unlike casebooks
used in the curricu la of most law schools, this publication is much more of a
nuts-and-bolts approach to solving specific problems that arise in everyday
tax practice. One of the unique features I have employed is the injection of
tricks and techn iques that go well beyond the boundaries of rigid procedural
rules. Unfortunately, this requires the injection of my own personal biases and
sometimes irreverent opinions, which may differ from those of mainstream
practitioners of this often frustrating art.
The incredible complexity of the Internal Revenue Code, which has
evolved over the past hundred years, has spawned an industry comprising
tax lawyers and accountants who deal primarily with the labyrinthine sub-
stantive tax rules. Simplicity is a concept foreign to the drafters of federal tax
law. In any event, the focus of practitioners on substantive tax rules, while
well understood, is often misplaced. What you will not find in this book are
any substantive tax law rules. Instead, I deal primarily with Internal Revenue
Code sections 6000 to 9000. It is my steadfast belief that without a thorough
knowledge of these procedures, the most learned tax practitioner will encoun-
ter nothing but frustration.
If there is a moral higher ground for the tax professional, it is undoubtedly
the desire to change the tax structu re systemically. Those of us who lack the
courage or inclination to do that are relegated to the mundane world of dealing
with the tax system as we find it—and not as it ought to be. I am frequently
asked, “Wouldn’t it be a much fairer tax system if only . . . ?” My answer is
always the same: “Yes, of course, but the chances of that happening, given the

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