From the Other Side of the Table: An Ex IRS Agent Perspective on What Makes R&D Tax Credit Work Credible.
By Jon Dolen, Tax Controversy & Strategic Account Advisor, DST Advisory Group
I am a former IRS Agent with 35 years of service, including 26 years of extensive experience in R&D tax credits. I’m fortunate to work with an outstanding team at DST Advisory Group, where I’m able to share my knowledge and experience.
Tyler, our Director, is highly effective at providing direction, consistently offering insight and foresight that keeps me on track. Philip, our RTC Manager, is thoughtful and collaborative, regularly contributing ideas and concepts that help guide my work. Jesse, our Senior Engineer and Tax Controversy Specialist, who previously worked in IRS Appeals, excels at reviewing write-ups and elevating them to a higher level.
Jesse reminds me of Jan from IRS Counsel, who once provided constructive feedback that helped strengthen a case write-up that was ultimately sustained in U.S. Tax Court and affirmed by the 7th Circuit Court of Appeals. As Jan told me, I have a unique way of seeing things that others might overlook. I once joked with her that my mind is like a bowl of oatmeal in a microwave with a spoon in it—ideas sparking in every direction—and that I benefit from having someone help organize those sparks.
We truly have a great team at DST. Currently, we are working on a state audit that began with the auditor proposing only a 10% allowance. That position has since evolved to one-third, then two-thirds, and now we are actively responding to a recent document request to refute the auditor’s current stance and pursue a greater allowance for the R&D tax credit.
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