TREA uses a disciplined, repeatable methodology to address IRS, New York State, and New York City tax matters, including audits, examinations, collections, sales tax issues, payroll tax issues, and related enforcement actions.
This All-Process Resolution Approach applies regardless of the type of tax issue involved. While outcomes vary by case, the process remains consistent.
Review, Stabilize, and Establish Case Control
This phase may include:
Review of IRS, NYS, and NYC notices and correspondence
Analysis of account transcripts and balances
Identification of engagement scope, deadlines, and enforcement posture
Evaluation of filing status and compliance gaps
Requesting collection holds or enforcement pauses where appropriate
Preliminary screening of potential resolution paths (audit defense, payment arrangements, settlement feasibility)
Phase 1 determines what is possible and what must be addressed first. No resolution strategy is selected at this stage.
Compliance and Financial Positioning
Phase 2 begins only when corrective action is required to support a defensible resolution strategy.
This phase may include:
Addressing unfiled or amended returns
Resolving withholding or estimated tax issues
Quantifying liabilities accurately
Preparing required financial disclosures
Organizing documentation for audits, appeals, or negotiations
Detailed financial disclosures and compliance corrections belong in Phase 2—not before.
Resolution Strategy and Implementation
Once the case is understood and properly positioned, resolution strategies may be pursued.
Depending on the circumstances, this phase may include:
Audit resolution or appeals
Negotiation of installment agreements or payment arrangements
Evaluation and submission of Offers in Compromise
Resolution of sales tax or payroll tax enforcement matters
Post-resolution monitoring, when appropriate
The resolution strategy is driven by facts, documentation, and procedure—not assumptions or preferences.Phase 1 determines what is possible and what must be addressed first. No resolution strategy is selected at this stage.