Strategy

Strategy is the governed answer to a question Discovery opens: we understand what the IRS has on file — what should we actually do about it? That answer is never a single program checkbox. It is a sequenced plan that respects filing compliance, collection posture, financial reality, and the client's life over the next several years.

Discovery (from IRS transcripts and intake) establishes Tier IRS facts: balances, assessments, enforcement signals, compliance gaps, and CSED timing. Strategy ranks realistic resolution paths against Tier 433 financials and Tier client circumstances — then documents the sequence your firm will defend in writing.

RESO can surface program options and caution flags from ledger and intake data. It does not replace practitioner judgment. The Strategy report is where you record why one path was recommended, which alternatives were considered, and what must happen first — before implementation fees are quoted.

First: what needs fixing on the IRS record?

Before ranking OIC, IA, CNC, or penalty relief, resolve structural blockers shown on transcripts and confirmed in intake. Skipping this step produces quotes the IRS will not process and fee disputes when the client expected a program that was never available.

Missing returns

Unfiled modules (no TC 150 where income exists on Wage & Income) block most collection alternatives. The Strategy sequence usually lists prepare-and-file originals before program selection. See the missing-returns playbook on the transcript guide.

Missing returns playbook →

Substitute for Returns (SFRs)

SFR assessments (often TC 971 AC 141) use third-party data without deductions or correct filing status. Strategy must separate SFR liabilities from taxpayer-filed years. Correcting an SFR typically means an original return and audit reconsideration (IRM 4.13) — not Form 1040-X — before OIC or IA math is trustworthy.

SFR playbook → · IRS reference

Amendments and return corrections

When the filed return understated liability, an amended return may be required before the IRS will accept certain programs — or may be strategically preferable to reduce balance before IA/OIC. Transcripts show TC 290/300 adjustments; they do not show whether an amendment is still in the mail. Strategy should note pending corrections and re-pull transcripts after posting.

Balances and assessments

Build a year-by-year matrix: assessed tax, penalties, interest, filing status, CSED, enforcement flags. Multi-year cases rarely use one program for every module — PPIA may pay down long-CSED years while short-CSED years expire.

Multi-year balance playbook →

Immediate collection issues

Active levy (TC 668), imminent levy risk, passport certification (TC 971 AC 641), or revenue officer assignment change urgency. Strategy may front-load levy release, CNC, or streamlined IA before longer OIC investigation — even when OIC is the long-term goal.

Collection activity playbook →

When acting now vs. waiting

Act now when enforcement is active, statutes are short, or exam is open. Waiting may be appropriate when compliance work will materially change the balance (SFR correction, penalty abatement posting), when CSED expiration favors monitoring, or when the client's circumstances will improve documented ability-to-pay — but waiting is a documented choice, not passive hope.

Realistic resolution paths — practitioner analysis

Each path below is a framework for professional judgment — not a guarantee of eligibility. Requirements and thresholds change; verify current IRS forms and instructions before filing.

Account for the taxpayer's actual life

The lowest payment is not always the right strategy. Practitioners weigh expected changes in income, housing, family, health, and retirement — against CSED timing and IRS processability rules.

Expected retirement or income drop

Future income may support CNC now and IA later — or make PPIA-to-CSED more attractive than a large OIC payment from retirement accounts.

Job change or business wind-down

Document timing; IRS may impute income if change looks voluntary without plan.

Housing, divorce, dependents

Household size and allowable expenses change RCP and IA payment — must match 433 and client story, reconciled to transcripts.

Major necessary expenses

Medical, court-ordered payments, and other categories may exceed standards with documentation — affects CNC and OIC.

Asset sales and equity

Transcripts do not show current home equity; Strategy must integrate appraisal and lien priority before OIC.

Future ability to pay

OIC future income multipliers embed expectations — document why imputed income is or is not fair.

The right sequence might be: become compliant → correct SFR → abate penalties → PPIA while CSED runs → revisit OIC only if circumstances change. Strategy documents that sequence so the client and the firm share the same expectation.

Worked strategy sequences

From Strategy to implementation and proof

Once Strategy is sold, the same case record seeds implementation — attested steps, IRS deadlines, and program tracking. When the engagement ends — or when a client questions fees — Work Verification assembles deliverables and payments into a defensible record. Understand → decide → do → prove.

Continue the journey