Kunkel v. Commissioner

EASTERBROOK, Circuit Judge.

After conducting an audit of the returns that Integra Engineering and its principal owners, Craig and Kim Kunkel, had filed for 2008, 2009, and 2010, the Internal Revenue Service concluded that they owed more taxes. The Kunkels hired Frank W. Bastían, a lawyer and CPA, to represent them and the firm in an effort to persuade the IRS otherwise. As the statute of limitations for the 2008 tax year approached, the IRS asked Bastían to sign a waiver that would permit the IRS to delay making its assessment. Taxpayers often agree to such waivers, thinking that continuing…