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Compliance

Tax Controversy Support

For clients responding to notices, support requests, and agency friction that require organized technical follow-through.

The problem

A notice or examination is not a moment for improvisation. Tax Controversy Support brings organized, technical follow-through to agency friction — framing the issue, assembling the documentation, and carrying the response to resolution rather than reacting to it piecemeal.

Who it’s for

Built for a specific kind of decision.

  • Businesses and complex individual taxpayers responding to notices or examinations
  • Owners and finance leaders managing agency friction or information requests
  • Clients who need a documented, defensible response carried through to resolution

Scope of work

What the engagement covers.

Notice response

Organized, on-time responses to notices and information requests — composed, not scrambling.

Issue framing

The matter framed on its strongest defensible footing before a position is advanced.

Documentation support

The record assembled to support the position under professional and agency review.

Resolution strategy

A coordinated path to resolution, with the steps and the timeline made clear throughout.

How Fortress works

One method, applied to this work.

The Fortress Hold Method is our way of turning complex tax facts into durable positions — a deliberate, five-step sequence built to hold under audit, professional review, and time.

Controversy work draws on the same standard applied before filing: a position is built to be defensible, and the documentation is assembled to hold under scrutiny.

  1. 01Define the facts
  2. 02Evaluate exposure
  3. 03Build the structure
  4. 04Coordinate execution
  5. 05Monitor change over time

Related insights

Tax Alert

2026 · 6 min

IRS Conservation Easement Settlement: 90-Day Window, 10% Penalty — Then Terms Worsen

On May 13, 2026, the IRS announced IR-2026-65, a time-limited settlement initiative for more than 1,100 syndicated conservation easement disputes — roughly 740 docketed in Tax Court and 400 still in examination. Eligible taxpayers who accept within an initial 90-day window concede the charitable contribution deduction (recovering only an "other deduction" for approximate out-of-pocket costs) and pay a 10% gross valuation misstatement penalty under § 6662(h); that penalty rises to 20% in a subsequent, final 45-day window, with no extensions. Decline, and the case reverts to a hazards-of-litigation posture against a record in which courts have allowed, on average, about 6% of the claimed deduction and generally imposed 40% penalties.

Read insight

Analysis

2026 · 4 min

An ERC Disallowance Starts a Two-Year Clock — and the IRS Just Built a Pressure Valve

A denied Employee Retention Credit claim is not the end of the matter, but it does start a clock: a taxpayer generally has two years from the disallowance letter to resolve the claim or sue for the refund. In April 2026, the IRS introduced a process — Notice CP320B and Form 907 — to extend that deadline for taxpayers still waiting on the agency to review their response. For businesses with claims caught in the backlog, this is the difference between preserving the right to sue and losing it.

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Analysis

2026 · 5 min

The IRS Is Withdrawing Its Partnership Basis-Shifting Rules — Read the Tempo, Not Just the Headline

In March 2026, Treasury proposed to remove the reporting regulations that, a year earlier, had branded certain related-party partnership basis adjustments as "transactions of interest." Combined with a sharply smaller IRS workforce, the move reads like a retreat from partnership enforcement. It is a real reduction in disclosure exposure — but it is not a signal that aggressive structures have become safe. The substantive law has not changed, and the cases still in litigation are being decided for the government.

Read insight

Related industries

Sector environments where this work most often changes the answer.

All industries

Start here

Start with the situation, not the tax controversy support brochure.

We begin by defining the facts and the timeline before recommending scope. If tax controversy support is the right fit, we will say so — and if it is not, we will say that too.

Speak with a Fortress advisorAll services

A licensed CPA firm with CPAs on staff. Typical first response within one business day.