Sometimes the question is “what’s the right answer?” not “what’s the strategy?” A client is about to do something (sell a business, restructure an entity, complete a 1031 exchange with an unusual fact pattern, take a position on a return that’s not clearly addressed by the regulations) and they need a defensible answer in writing before they act. That’s tax consulting and research as a discrete deliverable: a memo, an opinion, a citation-backed analysis that says here’s what the law actually requires, here’s the support, and here’s what the risks look like.
I’m Lawrence Israeloff. I’m a tax attorney and a CPA, and I’ve been doing this kind of focused-research-and-opinion work for clients across Long Island and the New York City metro for over two decades. Most of it is for closely-held business owners, fiduciaries, and individual professionals with situations that don’t fit a standard playbook – and for other CPAs and attorneys who need a second opinion or specialized research on a question outside their usual practice.
When the question needs research, not just strategy
A few patterns where this kind of work tends to come up:
- Transaction-specific tax questions. A real estate investor is contemplating a §1031 exchange involving a partial-interest property and wants to know whether the structure qualifies. A business owner is selling and needs to know whether the deal can be structured as a §338(h)(10) election versus an asset sale and what each looks like net of tax. A family is considering a §1202 qualified small business stock exclusion and needs to confirm the company met the original-issuance, active-business, and aggregate-asset requirements at the relevant times. Each of these turns on specific facts and specific Code provisions, and the wrong answer is expensive.
- Multi-state and residency questions. New York’s residency rules (the statutory residency test for the 183-day rule, domicile-versus-residence distinctions, the convenience-of-the-employer rule for telecommuters) produce hard questions for clients with property, work, or family ties in more than one state. The questions often have to be resolved before the client takes an action (selling a business, making a move, taking a remote job), not after. Written analysis at the front end is dramatically cheaper than litigation at the back end.
- Positions on returns that need authority behind them. Some return positions are mechanical; some require judgment about whether the law supports the position taken. When the position is ambiguous (a deduction that arguably qualifies, a characterization that has reasonable arguments on both sides, an exclusion that depends on facts that aren’t perfectly documented) the question becomes whether to take the position, whether to disclose it adequately on Form 8275, and what the penalty exposure looks like if the IRS disagrees. A research memo that walks through the authorities and concludes on the position protects against substantial-understatement and accuracy-related penalties under §6662.
- New legislation, new regulations, new guidance. Tax law moves. The Tax Cuts and Jobs Act in 2017, the SECURE Act and SECURE 2.0, the One Big Beautiful Bill Act in 2025, the steady stream of IRS notices and revenue rulings – each new piece of guidance creates questions about how it applies to existing client situations. When a client’s situation falls in the gap between old and new rules, or where the new guidance is unclear, research is the only way to a defensible answer.
- Questions that other professionals refer in. A meaningful share of this work comes from other CPAs and attorneys who have a client with a question outside their usual area (equity compensation, fiduciary income tax, multi-state issues, estate and gift technical questions, consolidated return rules, partnership tax) and who want a focused research deliverable they can rely on. The dual credential matters here: a CPA can rely on a tax attorney’s opinion for purposes of penalty protection and reasonable-cause defenses in ways that pure CPA-to-CPA referrals don’t accomplish.
What the deliverable actually looks like
A research memo or tax opinion is a document, not a conversation. The version I produce typically includes: a statement of the facts as the client has presented them, with explicit assumptions noted; a statement of the question or questions being addressed; an analysis of the relevant authorities (Code sections, Treasury Regulations, revenue rulings and procedures, case law, and IRS published guidance) applied to the facts; a conclusion stating the answer with the level of confidence appropriate to the analysis (will, should, more likely than not, reasonable basis, depending on the strength of the support); and a discussion of what the client needs to do to support the position if challenged.
For some engagements the deliverable is a formal opinion letter at a defined level of confidence; for others it’s a research memo intended to inform a decision; for others it’s a structured email response with the same analytic substance in a more compact form. The shape of the deliverable depends on what the client actually needs, not a one-size-fits-all template.
The research process
Tax research isn’t web search. It’s the systematic application of authority hierarchy – starting with the Internal Revenue Code, then Treasury Regulations, then revenue rulings and procedures, then private letter rulings (which are not binding precedent but are indicative), then case law from the Tax Court, federal district courts, courts of appeals, and the Supreme Court, then secondary sources like the AICPA’s tax guidance, leading treatises, and the AICPA Statements on Standards for Tax Services. Different authorities have different weight; conflicting authorities have to be reconciled or distinguished; the absence of authority on a point sometimes itself supports a conclusion.
The work product reflects that hierarchy. Citations are specific (§ section, Reg., Rev. Rul., docket and case name) and the analysis explains why the cited authority controls the question, not just that it exists. That’s the difference between a research deliverable a client can rely on and a Google-search summary.
Who I work with
The recurring patterns: closely-held business owners with specific transaction questions; high-income individuals with multi-state, equity compensation, or unusual income situations; trustees and executors with technical fiduciary income tax questions; real estate investors with basis, exchange, or characterization questions; clients facing IRS or NY DTF notices where the underlying question is technical rather than procedural; and other tax professionals (CPAs, financial planners, business attorneys) who refer clients in for specialized research or second opinions.
If your question is genuinely simple and the answer is clear from a basic IRS publication, you may not need this kind of work product, and I’ll tell you that. The research engagements that justify the cost are the ones where the dollar consequences, the audit exposure, or the precedential value of getting it right justifies a serious analysis.
Long Island, NYC, and the surrounding metro
I am text block. Click edit button to change this text. Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.I work out of Melville, NY and serve clients across Long Island, the five boroughs, Westchester, and the broader New York metro, plus referrals from professionals across the country with NY-specific questions. New York’s tax landscape (the state’s residency rules, NYC’s separate income tax structure, the PTET election regime, and the state’s aggressive enforcement posture) produces a steady stream of consulting questions that benefit from local expertise. Useful starting points if you want to read on your own: the IRS and the New York State Department of Taxation and Finance. Neither of those replaces a written analysis tied to your specific facts.
Let's talk
If you have a tax question that needs a defensible answer in writing before you act on it, that’s the conversation. Schedule a consultation and we’ll talk through what you’re trying to resolve and what kind of work product would actually answer it.
