The quality of a tax plan is significantly determined by whether it can survive examination. A plan that produces large theoretical savings but cannot be defended if questioned by the IRS is not a valuable plan; it is a future liability. The strategies that actually deliver value over time are the ones whose positions are clearly supported by the Internal Revenue Code, the Treasury Regulations, the IRS guidance, and the case law.
AE Tax Advisors has built its planning practice around producing tax plans that are explicitly grounded in the authority that supports each recommended position. Every strategic tax plan delivered by the Billings, Montana firm includes specific IRC citations for each strategy recommended, alongside the estimated dollar savings and the phased implementation timeline.
The reasoning behind this approach is structural.
The first reason is the audit defense posture. When a tax position is questioned by the IRS, the defense rests on the authority supporting the position. A plan that simply asserts “you can deduct this” without citing the underlying code section is fundamentally different from a plan that says “you can deduct this under IRC §X with supporting documentation Y.” The cited plan is defensible. The asserted plan is not. AE Tax Advisors clients receive defensible plans by design.
The second reason is the client’s understanding. A tax plan that the client cannot read or understand cannot be a basis for the client’s decisions. When the recommendations are cited to specific code sections and regulations, the client can evaluate the analysis themselves, ask informed questions, and make planning decisions with genuine understanding of what the positions actually rest on. This is meaningfully different from generic advice that the client must take on faith.
The third reason is the coordination with other professionals. The client’s attorneys, financial advisors, and other professionals need to understand the tax positions in order to integrate them into their own work. Cited tax plans support this coordination because each recommendation can be evaluated by the other professionals against the cited authority.
This is significantly more useful for multi-professional team coordination than uncited recommendations.
The fourth reason is the ongoing monitoring. Tax law changes through legislation, regulations, court decisions, and IRS guidance. When the original plan is built around specific cited authority, monitoring the changes becomes structured; the firm watches for changes affecting the specific provisions the plan relies on. Uncited plans cannot be monitored systematically because there is no defined authority to track.
The fifth reason is client trust. Sophisticated business owners and high-income professionals, the AE Tax Advisors client profile, typically expect that their advisors can defend recommendations with specific authority rather than asserting positions without support. The IRC-cited approach is what these clients expect from a serious advisory relationship.
The mechanics of the AE Tax Advisors plan structure involve several specific components.
Each strategy in the plan is described in plain language explaining what the strategy is and how it would work in the client’s specific situation. The plain-language description is followed by the specific Internal Revenue Code section, Treasury Regulation, Revenue Ruling, or other authority that supports the strategy. Where case law has been particularly influential in establishing the strategy’s validity, key cases are referenced.
Each strategy includes an estimated dollar savings amount calculated specifically for the client’s situation. The estimate is based on the client’s actual financial data, projected forward under reasonable assumptions, with the calculation methodology documented so the client can see how the estimate was derived. This is different from generic “potential savings up to $X” framings that don’t reflect the client’s specific situation.
Each strategy includes a phased implementation timeline showing when the work to execute the strategy should occur. Some strategies need to be implemented before the start of the tax year. Some need to be completed mid-year. Some are end-of-year actions. The timeline ensures the client understands when each piece of work needs to happen.
The plan as a whole is integrated across the strategies. Tax planning works because the strategies interact: entity structure affects retirement plan options, real estate strategy affects passive loss treatment, multi-state planning affects state tax, equity compensation timing affects bracket management. The integrated plan reflects these interactions rather than treating each strategy as isolated.
The plan also includes the documentation requirements for each strategy. Tax positions require documentation to support them, substantiation of expenses, contemporaneous records of activities, supporting analyses for valuations and reasonable compensation, and various other documentation depending on the specific strategy. The plan specifies what
documentation the client should maintain to support each position.
The annual $7,800 advisory engagement at AE Tax Advisors includes the complete strategic plan as one of the foundational deliverables. The plan is updated annually as the client’s situation evolves and as the tax law changes. The quarterly check-ins revisit specific components of the plan to ensure implementation is proceeding correctly. The mid-year projection identifies any adjustments needed based on actual year-to-date activity.
The firm’s team, IRS Enrolled Agents and licensed CPAs led by Christina Nortman, has built the IRC-cited plan approach into the firm’s operating standard. The work requires more analytical depth than uncited general advice, but the resulting plans are substantially more valuable to clients across the dimensions that matter: audit defense, ongoing coordination, client understanding, and long-term durability.
For business owners and high-income professionals who want tax plans they can actually understand and defend, the AE Tax Advisors approach represents one of the cleaner expressions of how serious tax planning should be structured. The work is technical. The plans are documented. And the team has the expertise to execute the approach across the breadth of strategies the firm operates.
Disclaimer: This article is for informational and promotional purposes only and does not constitute legal, tax, accounting, or financial advice. Tax laws, regulations, administrative guidance, and court decisions may change, and their application depends on each taxpayer’s specific circumstances. References to potential tax savings, audit support, defensibility, or other outcomes are illustrative and do not guarantee results. Readers should consult a qualified tax professional, CPA, Enrolled Agent, or attorney before implementing any tax strategy. Any descriptions of AE Tax Advisors’ services, pricing, credentials, processes, or client outcomes are based on information provided by the firm and should be independently verified.
