Responding to Adverse IRS Audit Assessments: Audit Reconsideration Requests, IRS Appeals, Settlement Strategies

Ms. Bullet is the Principal and Tax Controversy Service leader at Windham Brannon, where she advises individuals, closely held businesses, and high-net-worth clients on complex federal and state tax matters, including IRS examinations, appeals, collections, and controversy resolution strategies. She brings over 20 years of experience in both tax and audit. Before joining Windham Brannon, Ms. Bullet spent nearly 15 years with the Internal Revenue Service (IRS) in the Small Business/Self-Employed (SB/SE) Examination Division, where she led and managed examinations involving partnerships, corporations, and high-net-worth individuals. Prior to the IRS, Ms. Bullet began her career with PricewaterhouseCoopers, LLP in the Assurance practice and later served as an Internal Auditor with BellSouth Corporation. She is a frequent speaker on tax controversy and IRS enforcement topics and has presented for the American Bar Association, the National Bar Association, NYU Tax Forum, and various state and local tax organizations. Ms. Bullet is also a published author, with work featured in Taxes – the Tax Magazine and has been quoted as a subject matter professional in Bankrate.com. She earned her Master of Taxation from Georgia State University and a Bachelor of Science in Accounting from Tuskegee University. Ms. Bullet is a licensed CPA, serves on the AICPA Advocacy and Relations Committee (ARC), and is recognized by Forbes as a Best-in-State CPA. 

Mr. Kramarz is a principal in Kaufman Rossin’s tax services advisory group, leading the Tax Resolution & Advisory practice. He assists clients in all complex matters before the Internal Revenue (IRS) Service including examinations, appeals and dispute resolution, with specialized expertise in transfer pricing, financial products, foreign information reporting, collection alternatives, penalty relief, and multi-state tax issues. Mr. Kramarz has over 14 years of experience as an attorney assisting clients navigate the Internal Revenue Service (IRS), bringing direct experience with IRS examinations, the Appeals process, and collections. He represented the IRS in over 200 engagements in and out of Tax Court, most recently as a Special Trial Attorney, and rendered legal advice in domestic and international disputes. Since joining Kaufman Rossin in 2022, he has successfully resolved numerous IRS examinations and appeals. This includes employee retention credit cases, the abatement of large foreign information return penalties, and examinations of high-net-worth individuals. Michael also assists clients with complicated tax research and planning. Mr. Kramarz was responsible for litigating the largest and most complex tax controversies, managing litigation teams of attorneys, paralegals, and support staff, hiring, and working with expert witnesses, managing electronic document databases, coordinating with subject matter experts, and briefing executives. As a tax specialist, he has broad experience in reviewing transactions and tax planning, developing specialties in transfer pricing, Subpart F, and the taxation of financial products across various industries including, manufacturing and retail, finance, healthcare, real estate, construction, technology, and entertainment businesses.